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Compliance Specific News & Resources for GoWest Credit Unions
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Compliance Newsletter

COMPLIANCE HEADLINES

Consumer Financial Protection Bureau (CFPB) 


CFPB Blog: Servicemembers Continue to Face Major Financial Challenges 


The CFPB issued a blog post which focuses on challenges faced by servicemembers and highlights the protections they are entitled to under the SCRA.  The blog provided insight into three key areas: 

  • As interest rates remain high, too many companies still fail to provide servicemembers reduced rates on loans they took out before military service; 

  • Protecting servicemembers from military allotment system abuses; and 

  • Protecting servicemembers from identity theft. 


CFPB Issues New Report on State Community Reinvestment Laws 


The CFPB published an analysis on state Community Reinvestment Act laws, highlighting how states ensure financial institutions' lending, services, and investment activities meet the credit needs of their communities. The report examined the laws of seven states (Connecticut, Illinois, Massachusetts, New York, Rhode Island, Washington, West Virginia) and the District of Columbia, and found that many of those states adopted laws similar to the federal Community Reinvestment Act in decades following the 1977 passage of the landmark federal anti-redlining law. 


While the federal Community Reinvestment Act law applies strictly to banks, state reinvestment laws can apply to a wide range of financial institutions, including credit unions and nonbank mortgage companies. Banks now originate and hold a much smaller share of outstanding mortgage debt than they did when the legislation was originally enacted. In 1977, banks held 74% of outstanding mortgage debt. By 2007, this share had declined to just 28%. As of 2021, nonbank mortgage companies originated 64% of conventional home purchase mortgage loans, compared to the 25% originated by banks. 


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Arizona Families Tax Rebate 


Recently the Arizona Families Tax Rebate was deployed, which is aimed at providing financial relief to nearly 750,000 families in the state. 


What is the Arizona Families Tax Rebate? 

This rebate, the first of its kind, is a result of the state budget that passed earlier this year. Eligible families can anticipate receiving up to $750 in tax rebates, offering a vital financial boost in the face of rising costs and inflation. 


How Does It Impact Credit Unions? 

As credit unions, you can expect to see direct deposits related to the Arizona Families Tax Rebate landing in your members' accounts. In addition, credit unions should be prepared to address questions from credit union members. 


Where can Members Find Eligible Criteria? 

The eligibility criteria, along with a full FAQ can be found on the AZ Department of Revenue Website


How can Members Check Their Rebate Status? 

Members can visit the Arizona Families Tax Rebate Portal to check their rebate status. 


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Audit the Audits – First Amendment Audits 

  

A recent trend referred to as Audit the Audits or First Amendment Audits has become the ‘thing’ on social media.  The majority or the videos are posted on YouTube.  The practice encourages its members to take pictures or videos from public spaces. Often the videos are of financial institutions, restaurants, and government buildings.  The goal is to provoke a challenge to their 1st amendment right to take the pictures and hopefully have law enforcement called.  The encounter is then put on social media with the intent of shedding negative light those being recorded. 


Here is a recent example of one of these audits that happened in the Northwest - https://www.youtube.com/watch?si=Ji7uDfQelOaylKB_&v=5PzAl7gjeJU&feature=youtu.be 


Credit unions may wish to have a discussion with the branches on what to do if they notice someone recording them, such as closing all of the blinds to create privacy within the branch.



League InfoSight Highlight

League InfoSight Highlight: CFPB Advisory Opinion – Keeping Up With Compliance! 


Keeping up with regulatory changes and ensuring compliance is challenging. Here are some of the top compliance tips and tools you can use to proactively navigate the ever-changing compliance landscape! 


Understand the Regulations 
Take the time to thoroughly understand the laws and regulations that apply to your credit union. This includes not just reading them but also understanding the intent behind them and how they impact your credit union’s operations.  
InfoSight is a free resource for affiliated credit unions which includes information for 15 major compliance areas written in simple terms that staff and board members can easily understand. Each topic includes a summary of the issue, how it affects credit unions, and what credit unions need to do about it. InfoSight also includes compliance checklists, FAQs, compliance videos, and state-specific information for all 50 states! 


Stay Updated 
The regulatory environment is constantly evolving, so staying on top of new and updated laws and regulations is essential. The quarterly compliance videos in InfoSight provide condensed overviews of timely regulatory topics that can help your staff and board stay informed and understand how changes may affect your credit union. Your InfoSight dashboard can be customized to provide updates on specific topics that are relevant to your position. CU PolicyPro and RecoveryPro content is reviewed quarterly, and content is created or updated as needed. Auditing tools make it easy to track and document changes, and assignments can be created to keep your staff engaged and keep policy review and maintenance on schedule. 


Document Everything 
Documentation is critical in compliance. Keeping a complete record of compliance activities provides an audit trail for your compliance program, helps with identifying and addressing compliance gaps or weaknesses, and provides consistency throughout the organization including during staffing changes. CU PolicyPro and RecoveryPro have multiple auditing tools to help document the entire life cycle of your policies, procedures, and Business Continuity Plan. ComplySight empowers credit unions to assess their regulatory compliance risk, identify areas of potential noncompliance, and document corrective action. ComplySight also includes a full Complaint Management System to track complaints, identify trends, and document resolutions and remediations. 


Conduct Independent Audits and Reviews 
It’s important to anticipate examiner expectations, mitigate risk, and employ a system of checks and balances to protect against fraud and provide effective internal operations. AffirmX, CU Risk Intelligence’s industry leading risk-management automation provider, is a cost-effective way to perform regulatory required independent audits and/or independent compliance reviews of different operational areas within the credit union. Your staff will have more time to correct deficiencies while an independent team helps find them! 


Ask Questions 
Don't hesitate to seek guidance! Your league/association is a great place to start. Contact the compliance hotline with your questions and concerns, participate in training and educational events, join networking groups to connect with peers who can offer insights and share best practices, and consider consulting and audit services. 


The League InfoSight support team (policysupport@cusolutionsgroup.com) is also a great resource if you have technical or content questions! 


Mary Ann Koelzer, 
Senior Technology Products Manager, League InfoSight 



ARTICLES OF INTEREST


NCUA Posts 2024-2025 Proposed Budget, Sets November 16 Public Briefing 


Fast Facts: Personal Data Financial Rights Proposed Rule 


Consumer Compliance Outlook: Second/Third Issue 2023 


401(k) limit increases to $23,000 for 2024, IRA limit rises to $7.000 


FinCEN Identifies Jurisdictions with AML/CFT Deficiencies 


SCAM UPDATES


Fast Cash for a Monthly Fee with Brigit App? Not so Fast 


Veterans and Scams 



COMPLIANCE CALENDAR

Nov 10, 2023: Veterans Day - Federal Holiday (Observed) 


Nov 23, 2023: Thanksgiving Day - Federal Holiday 


Dec 25, 2023 – Christmas Day – Federal Holiday 


Dec 29, 2023 – Comments Due CFPB Proposed Rule on Personal Financial Data Rights 


TOOLS & RESOURCES

Effective Dates
Bulletins & Alerts
Webinar Calendar
AffirmX and GoWest Partnership

Q&A OF THE WEEK

The credit union is going to give members a special credit card to access their HELOCs. Do we need the Schumer Box disclosures? 


The credit union does not have to provide the Schumer Box disclosures on or with applications and solicitations for credit cards that access a HELOC. 

Regulation Z, Section 1026.60(a)(5)(i) covering exceptions to the general rules for credit and charge card applications and solicitations, states that the rules including the requirement for disclosures provided in the Schumer Box do not apply to home-equity plans (HELOCs) that are accessible by a credit or charge card. Therefore, applications and solicitations for credit cards that access a HELOC do not have to contain a Schumer Box. 


12 CFR 1026.60 


For your individualized login, select your state below. 

Arizona
Colorado
Idaho
Oregon
Washington
Wyoming

If you have questions about this communication, contact us at 800.546.4465, or via our shared email inbox at compliance@gowest.org.

Have a great week!

Your GoWest Compliance Team, 

David Curtis

CUCE

Director, Compliance Services
P: 206.340.4785

Tiarra Sanders-Hausa

NCCO

Manager, Compliance Services

P: 206.618.9302

Copyright © 2023 GoWest Credit Union Association. All Rights Reserved.

Mailing Address:
GoWest Credit Union Association, 18000 International Blvd, Ste. 1102, SeaTac, WA 98188, United States
1.800.995.9064

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