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Compliance Monitor: The what, why, how and maintenance of protected balances
NAFCU's January Compliance Monitor – now available for download – provides association members with the "what, why, how and the endless maintenance" of protecting credit union members' credit card account balances in connection with a rate or fee increase.
"While protected balances are a key consumer protection to prevent predatory lending practices, they cause quite a bit of confusion and frustration for credit unions," writes NAFCU Regulatory Compliance Counsel Jennifer Aguilar.
Describing the protected balance requirements of the Credit Card Accountability Responsibility and Disclosure Act of 2009 (the Credit CARD Act) in her article, Aguilar uses various examples and visuals to help credit unions understand their responsibilities. She outlines how the creation of the protected balance is tied to the change in term notice requirements, the various operational changes the law presents to credit unions and those rules that apply after the protected balance has been created.
This month's Monitor also includes the Compliance Forum, featuring questions and answers on issues such as the Fair Credit Reporting Act, lending to a limited liability company, Home Mortgage Disclosure Act (HMDA) implementation and share certificate maturity notices.
More of NAFCU's award-winning compliance resources can be found here.
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