August 17, 2023

New on the Compliance Blog: ATMs and checks, CFPB Supervisory Highlights

Compliance BlogAs credit unions work to meet the needs of more than 137 million Americans, NAFCU's award-winning regulatory compliance team continues to keep credit unions informed with new posts on the Compliance Blog every Monday and Wednesday.

Here's a roundup of what's new this week:

On-Us Checks Deposited at a Proprietary ATM and Availability under Regulation CC: Regulatory Compliance Counsel Tara Simpson explains when funds from an “on-us” check deposited at a proprietary ATM must be made available. She highlights that “which funds availability rule applies may depend on where the proprietary ATM is located.” For “on-us” checks deposited at an ATM at the branch, at least $225 must be made available “by the business day following the banking day of deposit. After that, it will follow the general check availability rules found in section 229.12”. For checks deposited at ATMs not at the credit union, Simpson notes “on-us check are required to be made available by the second business day after the deposit was made.”

Peering into the Future: 2023 Supervisory Highlights (Pt. 2)Regulatory Compliance Counsel Aminah Moore discusses the CFPB’s summer edition of its Supervisory Highlights. Moore reviews additional sections outlined in the document, such as auto loan marketing, pricing exceptions, discriminatory lending restrictions, and loss mitigation applications.

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