NAFCU addresses remittances, safe harbor with CFPB
NAFCU's Senior Counsel for Research and Policy Andrew Morris urged the CFPB to preserve credit unions' ability to provide remittance services by reinstating the temporary exception under equivalent, statutory authority. Morris also called on the CFPB to increase the safe harbor transfer threshold in response to the bureau's request for information (RFI) regarding its remittance rule.
The association has long expressed concerns about the rule's highly burdensome compliance costs and previously urged the bureau to exempt credit unions from the rule.
In his letter sent Friday, Morris notes that "since the 2012 Remittance Rule took effect, credit unions have incurred significant costs associated with the rule’s complex disclosure requirements and error resolution framework, and many have ceased offering remittances as a result."
Morris also recommended for the bureau to reconstitute the temporary exception allowing insured depository institutions to provide estimates of exchange rates and fees set by third parties to prevent "negative impact on credit unions’ ability to continue providing affordable remittance services."
NAFCU asks that the bureau increase the rule's current safe harbor threshold to at least 1000 transfers "improve consumer access to affordable remittance services at credit unions, regardless of whether the Bureau determines that the substance of § 1005.32(a)(1) (the temporary exception) can be saved." To provide alternative relief, the letter also requests that the Bureau consider adopting a credit union exception to the Remittance Rule.
Last year, NAFCU witness and Senior Vice President of Corporate Affairs & General Counsel John Lewis testified at a House Financial Services subcommittee hearing, sharing the challenges his credit union – United Nations Federal Credit Union – faced due to changes in remittance requirements, including increased costs for the credit union and their members. Lynette Smith, President and CEO of TruEnergy Federal Credit Union, also testified on the remittance rule's impact in 2012.
NAFCU will continue to push the CFPB to reduce the remittance rule's burden on credit unions.
Add to Calendar 2020-12-04 14:00:00 2020-12-04 14:00:00 Give Your Members the Gift of Fraud Protection for the Holidays The holiday season will look different this year for a lot of reasons. But one that many credit unions are gearing up for is new fraud attacks. Digital fraud and scams will potentially be worse than ever before, with the increase in digital shopping, and the commencement of holiday sales and black Friday deals. In order for you and your members to enjoy this season, you’ll want to be aware and prepared. So, we’re talking with Ann Davidson, Vice President of Risk Consulting at Allied Solutions, about how to get out ahead of these risks with key prevention methods and education for members. PROGRAM UNDERWRITTEN BY Key Takeaways What new forms of fraud should your credit union be prepared for this holiday season? How has this changed from previous years, given the pandemic’s impact? What can your credit union do to mitigate these risks? Register Now For On-Demand AccessRegistration is complimentary, but you must register to attend.One registration gives your entire credit union access to the on-demand recording until December 4, 2021.Already registered? Go to the Online Training Center to view live. Who Should Attend? NAFCU Certified Risk Managers (NCRMs) NAFCU Certified Compliance Officers (NCCOs) NAFCU Certified Bank Secrecy Officers (NCBSOs) Compliance staff BSA staff Risk staff Education Credits NCRMs will receive 1.5 CEUs for participating in this webinar. NCCOs will receive 1.5 CEUs for participating in this webinar. NCBSOs will receive 1.5 CEUs for participating in this webinar. CPA credit information is below; recommended 1.5 CPE credits. CPA Certification Credit Information Reviewer: Josie Collins, Associate Director of Education, NAFCU Learning Objectives: What new forms of fraud should your credit union be prepared for this holiday season? How has this changed from previous years, given the pandemic’s impact? What can your credit union do to mitigate these risks? Program Level: Basic Prerequisites Needed: None Advance Preparation Needed: None Delivery Method: Group Internet-Based Recommended CPE Credits: 1.5 credits Recommended Field of Study: Regulatory Ethics – Technical National Association of Federal Credit Unions (NAFCU) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. Learn more. About Our Webinars Our webinars are streamed live from NAFCU headquarters near Washington, D.C. Your audio/video feed of the presenters includes presentation slides and downloadable handouts. You can easily submit your questions to the presenters at any time during the live broadcast, with no dialing over the phone! The audio and video stream directly through your computer. Web NAFCU firstname.lastname@example.org America/New_York public
Credits: NCRM, NCCO, NCBSO, CPE
Program underwritten by NAFCU Services
Add to Calendar 2020-12-02 09:00:00 2020-12-02 09:00:00 The Evolving Credit Crisis- How Credit Unions Can Respond Now Listen On: Key Takeaways: [03:32] Banks are reporting minimum increases in the things you would expect to see as warning signs like charge-off rates and delinquency rates. [11:20] Sophisticated modeling techniques are models that are built from lots of historical information, can tie variables together, and anticipate credit losses. [17:29] The credit unions that have a good understanding of their membership, markets, loan portfolios, and the ability to get some insight into those analytics may see some opportunities to expand into other product types. Web NAFCU email@example.com America/New_York public
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