Tuesday Grab Bag; Group Photo from Seminar
Posted by Anthony Demangone
Here's some compliance-related odds and ends.
- The FTC has delayed the effective date of its Red Flags rule again, this time until June 1, 2010. Remember, the FTC's version of this rule does not cover federal credit unions. So the extension does not benefit you FCUs. I mention this news because the FTC announcement may confuse some within our industry. (Now, if only the FTC would talk to HUD about extending the RESPA deadline...)
- NCUA has announced that we can expect its proposed rule that will address corporate credit unions in its November 19th board meeting.
- I'm guessing it was not fun working at this Ohio bank recently. (Link to www.bankinfosecurity.com).  Someone walked in and took three storage bins that contained paper that was to be shredded. Oh, and each bin weighed 500 pounds. This would be a nice story to use to reinforce your security procedures. Along those lines, don't forget that Appendix B to Part 748 contains NCUA's guidance on response programs. If the incident noted above happened at your credit union, how long would it take you to respond as outlined in that guidance?Â
- NCUA, along with other regulators, adopts "Prudent Commercial Real Estate Loan Workouts" guidance. If your credit union does commercial real estate lending, this is a must read.
- Relatedly, NCUA issued Letter to Credit Union 09-CU-19 in September, to share a Supervisory Letter given to examination staff to help them evaluate residential real estate modification programs.  If your credit union is doing workouts, your examiner will likely scan this guidance before visiting your shop. Ergo, you should review it as well.
I guess that's enough. Enjoy your Tuesday!
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Here's a group photo of our Compliance Seminar attendees from Charleston. A full week of compliance, and they are still all smiling. Incredible! To all the attendees, thanks so much for attending. I hope you had as much fun as I. *
* (I always waffle on how to end that sentence. As much fun as I? Or as I had? Is the had implied? It sounds fancier to leave it out. But what do I know? Ugh.)