August 03, 2023

New on the Compliance Blog: Credit card disclosures, automated underwriting

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 thCompliance Blog every Monday and Wednesday.

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

Credit Card Applications, Solicitations, and the Delivery of Required Disclosures: Senior Regulatory Compliance Counsel Justin White explains when a credit union must provide credit card disclosures under Section 1026.60 of Regulation Z. White notes that credit unions who initiate contact with a consumer and includes an application must provide those disclosures.

Automated Underwriting: Is it a Fair Lending Concern?: Regulatory Compliance Counsel Judy Dahn highlights the joint agency guidance on potential bias in automated systems. Dahn notes that the NCUA has applied regulatory scrutiny when a credit union puts potential borrowers through a different underwriting process based on age. She adds that setting age parameters on an automated system “could increase a credit union’s fair lending and compliance risk.”

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