Upcoming Compliance Deadlines - Spring 2012
Written by Steve Van Beek
There are a few upcoming deadlines to make sure your credit union is making progress on. Â
HMDA Reporting. Â The deadline for HMDA submissions is March 1, 2012. Â NCUA issued a Regulatory Alert earlier this month - 12-RA-01 - that highlights the reporting deadline. Â
ADA & ATMs. Â The March 15, 2012 deadline for compliance with the ADA requirements for ATMs is quickly approaching. Â Remember, document your process and your communications with your vendors as it could be useful if there are delays and the CU faces a lawsuit. Â Â
The speech output requirements apply to all ATMs and need to be in place by March 15, 2012. Â The physical access requirements apply to ATMs that are altered after March 15, 2012. Â The physical access requirements also apply to any new ATMs added after March 15, 2012. Â Existing ATMs that comply with the 1991 ADA standards for physical access andÂ areÂ not alteredÂ would not need to be modified. Â Additional information is available in last month's blog post.
Durbin - Unaffiliated Networks. Â The requirement for unaffiliated networks goes into place on April 1, 2012. Â This requirement means credit unions need to have two unaffiliated networks - such as one PIN network and one signature network - for processing transactions. Â Additional information and details on this requirement can be found in our January 30th blog post.Â Â Â
NLRB Notice. Â Credit unions should be posting the National Labor Relations Board (NLRB) Employee Rights poster by April 30, 2012. Â A couple past NAFCU blog posts discussed this issue in more detail: Â January 4, 2012 andÂ December 2, 2011. Â