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Comments are due to the NCUA today on its proposal to delay its risk-based capital (RBC) rule by one year. NAFCU's compliance team continues to coordinate with the association's award-winning advocacy team to obtain a delay beyond its current implementation date of Jan. 1, 2019, in order to give credit unions more time to comply, especially as the NCUA considers additional changes to the original rule.

In addition to the NCUA's proposal, NAFCU's advocacy has made headway in Congress: a provision to delay the rule by two years has passed the House three times. The association will keep credit unions updated on the status of a delay and will submit comments to the NCUA today.

NAFCU's compliance team works daily to keep credit unions' compliance teams informed of the ever-changing regulatory environment – the team summarizes important regulatory changes in NAFCU's Compliance Calendar. Of note, on Sept. 1 the NCUA's second field-of-membership rule, finalized in June, went into effect. See below for upcoming dates and deadlines for credit union regulatory compliance requirements.

Sept. 17: The Bureau of Consumer Financial Protection (previously the CFPB) in August finalized its rule to amend Part 503 of the Gramm-Leach-Bliley Act (GLBA) as implemented in Regulation P. A December 2015 statutory amendment to the GLBA provided an exception to the annual privacy notice requirement for financial institutions, including all credit unions, so long as certain statutory requirements are met. It also removes the alternative delivery method for annual privacy notices and provides a 100-day time period for delivery of a required annual privacy notice in the event a financial institution that previously qualified for the annual notice exception later changes its policies or practices and no longer qualifies for the exception.

Oct. 1: The NCUA's final voluntary mergers rule becomes effective. The rule increases the minimum required time for notice to members before a merger vote to 45 days; requires the merging credit union to disclose merger-related financial arrangement increases above $10,000 or 15 percent of compensation, whichever is greater for covered persons; clarifies the contents and format of the members' notice to increase transparency; and establishes a portal for members of the merging credit unions to provide comments about the proposed merger to the NCUA on its website.

Oct. 1: The bureau's finalized amendments to its Truth in Lending Act (TILA)/Real Estate Settlement Procedures Act (RESPA) integrated disclosure (TRID) rule became effective October 2017, but mandatory compliance is required for applications received on or after Oct. 1. The amendments codify the bureau's previously issued informal guidance on the rule and provide additional technical clarifications. They also make adjustments to substantive issues related to tolerance provisions, recording fees and transfer taxes, cooperative units, separate disclosure forms, among others. NAFCU has various resources on the rule available here.

Download the latest NAFCU Compliance Calendar for more details.