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Compliance Blog roundup: Skip-a-pay, new paid leave requirements, NCUA webinar, more
NAFCU's award-winning Compliance Team is working around the clock to publish new Compliance Blog posts daily, Monday-Friday, to keep credit unions informed of important regulatory updates during the coronavirus pandemic. Here is a roundup of this week's blog posts.
Skip-a-Pay: NAFCU Senior Regulatory Compliance Counsel Jennifer Aguilar covers the considerations for closed-end consumer credit when allowing members to skip a payment. She addressed the rules for open-end credit in a previous blog. Aguilar notes that closed-end skip a pay arrangements are often more complex than open-end skip a pay arrangements, and suggests credit unions may want to work with local counsel to draft an appropriate modification agreement that meets all state and federal requirements.
Coronavirus Related Federal Paid Leave Requirements: Last month, Congress passed and the president signed into law the Families First Coronavirus Response Act (FFCRA). In Tuesday’s blog post, NAFCU Vice President of Regulatory Compliance Brandy Bruyere explains two key pieces to the FFCRA – the Emergency Paid Leave Act and the Emergency Family and Medical Leave Expansion Act – that went into effect Wednesday and will expire Dec. 31.
Mortgage Loan Modification: In response to questions from members who do not hold federally backed mortgage loans but would still like to offer a forbearance period, NACU Regulatory Compliance Counsel Loran Jackson explains what offering a forbearance might look like in practice and what strategies credit unions may employ when creating mortgage loan modifications agreements. Another blog post explains the mortgage loan forbearance and the requirements under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).
ICYMI - NCUA webinar: Brandy Bruyere offers a helpful summary information shared by the NCUA during a webinar offered Wednesday about its coronavirus response efforts. She notes that credit unions can offer the NCUA direct feedback or ask questions via email at COVID19questions@ncua.gov.
Credit Reporting After Offering Coronavirus Relief: Following previous blog posts about skip payments for open-end and closed-end credit and forbearance agreements, NAFCU Regulatory Compliance Counsel David Park explains what is required under the CARES Act if a credit union provides relief to its members during the national emergency, specifically when it comes to credit reporting.