NCUA, CFPB release fall rulemaking agendas
Federal agencies, including the NCUA and CFPB, released their fall 2022 regulatory agendas Wednesday. There are several NAFCU and credit union advocacy priorities included among the items, some of which have been previously introduced or included on rulemaking agendas.
Here are a few notable items included on the fall agendas; NAFCU will have additional insights available in the NAFCU Networks:
- Automated Valuation Models (AVMs): This interagency proposed rule would implement Dodd-Frank’s four quality control standards for the use of AVMs by mortgage originators and secondary market issuers as part of the process of determining the collateral worth of a mortgage secured by a principal dwelling. This item has been carried over from several previous rulemaking agendas, and more information can be found in NAFCU’s Insights post on the Fall 2021 agenda. NAFCU has asked the NCUA to prioritize its AVM rulemaking.
- Climate-Related Financial Risks: The NCUA is seeking public input on potential climate-related financial risks to federally insured credit unions, related entities, and the National Credit Union Share Insurance Fund (SIF).
- Federal Credit Union Bylaws: The board continues to work on finalizing a proposed rule to amend the federal credit union bylaws to implement the Credit Union Governance Modernization Act of 2022 related to the expulsion of members. NAFCU submitted comments to the agency Dec. 2, 2022.
- Simplification of Share Insurance Rules: Expected in early spring, the proposal would simplify the share insurance regulations by establishing a “trust accounts” category that governs coverage of shares of both revocable and irrevocable trusts using a common calculation and provide consistent share insurance treatment for all mortgage servicing account balances held to satisfy principal and interest obligations to a lender. The FDIC previously adopted a similar final rule.
- Subordinated Debt: The NCUA is considering amending its subordinated debt regulation as it applies to the duration of regulatory capital treatment of debt issued to government investors, as well as other possible changes. Comments on the proposed rule closed in December 2022. NAFCU submitted comments supporting the proposal.
- Succession Planning: A final rule to require FCUs to establish and adhere to succession plans for key positions, including board officers, management officials, and other positions identified in credit unions’ bylaws is tentatively planned for May. NAFCU opposed this proposed rule.
- Asset Threshold for Determining Supervisory Office: The final rule to increase the threshold for transitioning large credit unions to ONES supervision is set for this summer. NAFCU advocated for increasing the Tier I threshold to $20 billion in assets rather than the $15 billion Tier I threshold in the proposed rule.
- The NCUA’s agenda also includes a number of final actions on interim final rules related to COVID relief, including prompt corrective action and the Central Liquidity Facility, as well as several items carried over from previous rulemaking agendas.
- Fair Credit Report Act (FCRA): The bureau is considering whether to amend Regulation V, which imposes legal duties on consumer reporting agencies, data furnishers, and users of consumer reports, and furnishers of information to consumer reporting agencies. NAFCU filed several amicus briefs with other trades associations in 2022 to clarify the requirements of data furnishers in investigating credit disputes and confirm that the FCRA preempts state credit reporting laws.
- Section 1071 Small Business Lending Data: The bureau plans to finalize this rule to implement Section 1071 of the Dodd-Frank Act in March. NAFCU’s comment and a joint trades letter urged significant changes to the proposed rule to reduce compliance burdens imposed on credit unions.
- Section 1033 Personal Financial Data: The Small Business Regulatory Enforcement Fairness Act (SBREFA) panel is expected to release its report in February. NAFCU will provide comments to the bureau on the panel’s outline of proposals under consideration.
- Fees: The bureau has several items on its agenda related to fees, including overdraft, insufficient funds, and credit card penalties.
- Voluntary Information Sharing Under Section 314(b): NAFCU has asked FinCEN to improve the utility of the information sharing program by allowing financial institutions to share information about fraud. This item has been included in several previous agendas and a proposed rule is now scheduled for June.
Add to Calendar 2023-12-07 14:00:00 2023-12-07 14:00:00 BSA Back to Basics: CTR and SAR Filings From identifying when Bank Secrecy Act (BSA) regulations require filing a currency transaction report (CTR) and suspicious activity report (SAR) to learning how to tactically complete those forms, in this back-to-basics webinar, you’ll evaluate how to apply BSA requirements to transactions to determine when filings are required and how to complete the forms associated with those filings. Key Takeaways Learn the basics of BSA/AML regulations for CTR and SAR filing requirements Understand how to implement BSA/AML regulations at your organization to detect transactions that require a CTR and/or SAR Discover how to use the CTR and SAR forms in FinCEN’s BSA E-Filing system Receive a step-by-step walkthrough of completing CTR and SAR forms. Register Now $295 Members | $395 Nonmembers(Additional $50 for USB)One registration gives your entire team access to the live webinar and on-demand recording until December 7, 2024.Go to the Online Training Center to access the webinar after purchase » Who Should Attend NCBSOs NCCOs NCRMs BSA, compliance and risk titles Education Credits NCCOs will receive 1.0 CEUs for participating in this webinar NCRMs will recieve 1.0 CEUs for participating in this webinar NCBSOs will recieve 1.0 CEUs for participating in this webinar CPA credit information is below; recommended 1.0 CPE credits. CPA Certification Credit Information (Note: Webinars must be attended when aired to receive CPE credits.) Reviewer: Josie Collins, Senior Associate Director of Education, NAFCU Learning Objectives: See key takeaways Program Level: Basic Prerequisites Needed: None Advance Preparation Needed: None Delivery Method: Group Internet-Based Recommended CPE Credits: 1.0 credits Recommended Field of Study: Reguatory Ethics – Technical About Our Webinars Our webinars are streamed live from NAFCU headquarters near Washington, DC. 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: NCCO, NCRM, NCBSO, CPE
Add to Calendar 2023-12-07 14:00:00 2023-12-07 14:00:00 Breaking Down Silos: Collaborating to Combat Cyber Fraud About the Webinar With the rapidly evolving threat landscape, it is clear that operating in isolation is no longer a viable strategy for effective and proactive cyber risk management. The challenges presented by cyber threats demand a concerted effort within your credit union to break down silos and collaborate effectively. Your credit union’s information security and fraud teams must work together to develop a comprehensive and cohesive approach to managing cyber risks. In this session, we will explore how to leverage expertise and tools to be proactive in your fraud detection. Join DefenseStorm’s resident Fraud Geek and senior product manager, Adam Barrett where we will delve into how your credit union can: Evaluate edge data to better identify fraudsters hiding behind VPNs Cultivate effective relationships to combat fraud Efficiently engage with your red team Open up the dialogue around pain points or blind spots to improve your ability to stop cyber fraud Register Here Web NAFCU email@example.com America/New_York public
Add to Calendar 2023-12-06 09:00:00 2023-12-06 09:00:00 Navigating Student Lending: A 2023 Review and 2024 Outlook Listen On: Key Takeaways: [0:57] What were the biggest challenges and opportunities with regard to student lending and CUs in 2023? [2:55] We discuss the duality of education lending: in-school financing for younger individuals and post-graduation refinancing for lasting credit union engagement. [5:47] The credit union journey emphasizing its natural progression from student loans to auto and mortgage opportunities. [6:25] During the student loan repayment pause, credit unions benefited as borrowers saved money, but the impact upon resumption is expected to be manageable. [9:36] What were the most significant policy changes that impacted student lending and credit unions in 2023? [13:52] Predictions for student lending and CUs in 2024. [14:50] Long-term value in engaging young borrowers, highlighting lifetime financial opportunities. Web NAFCU firstname.lastname@example.org America/New_York public
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