National Credit Union Administration (NCUA) 

NCUA Releases Federal Credit Union Operating Fee Schedule for 2024 

The NCUA Board approved the agency’s 2024 operating and capital budgets. As a result of that decision and other factors, federal credit union operating fees will increase by an average of approximately 16.36 percent in 2024. Additionally, the operating fee exemption threshold was increased from $1 million to $2 million. Federal credit unions with a four-quarter average of $2 million or less in total assets are exempt from the operating fee. 

The increase in the 2024 operating fee results from budgetary growth at the NCUA and the lack of a 2024 operating fee credit for unspent fees collected in past years. The 2024 operating fee is based on the NCUA’s operating and capital budgets, which grew approximately 7 percent combined, between 2023 and 2024. The NCUA applied credits to the operating fee charges for 2022 and 2023 for the fees it collected but did not spend in 2021 and 2022, largely because of reduced travel spending during the COVID-19 pandemic. Travel-related spending increased in 2023, and the NCUA ended the year without sufficient balances to provide a credit to the 2024 operating fee. 

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Consumer Financial Protection Bureau (CFPB) 

CFPB Proposed Rule on Overdraft Credit 

The CFPB issued a proposed rule to amend both Regulations E and Z to update the regulatory expectations for overdraft credit provided by financial institutions with more than $10 billion in assets. 

The proposed rule would require larger financial institutions to structure their overdraft programs as covered overdraft credit, which is defined as overdraft credit that is subject to a finance charge or is payable by written agreement in more than four installments. The large financial institutions will need to structure their programs, so the overdraft credit is a separate account that is tied to the checking account. 

The large financial institutions will have the option of providing non-covered overdraft credit but will be limited in what they can charge.  Either a pro rata share of the total costs and charge-off losses for providing the overdraft credit or a safe harbor amount set by the CFPB. The proposed rule is looking at several options for this safe harbor amount. $3, $6, $7, or $14. 

Comments are due by April 1, 2024. 

League InfoSight Highlight: Compliance Q4 Video and LIS Product Update 

Now Available on InfoSight! 2023 Q4 Compliance Update Video 

Stay on top of federal regulatory changes with InfoSight’s Compliance Videos, highlighting developments related to Deposit Accounts, Lending, and Credit Union Operations. Some topics highlighted in the most recent update include: 

Deposit Accounts Updates 

• Status Update on FinCEN’s Beneficial Ownership Rule 

• Reminder that beginning January 1, 2024, reporting companies are required to file beneficial ownership information directly with FinCEN (“reporting rule”). FinCEN also plans to allow access to the database to 6 different categories of recipients (“access rule”).  

• Upcoming NSF/Overdraft Rulemaking 

• Overdraft Fees 

• Fees for Non-Sufficient Funds 

 Lending Updates 

• Threshold Adjustments for 2024 

• Home Mortgage Disclosure Act 

• Small Creditor 

• HPML Appraisal Exemption 

• Joint Statement on Immigration Status Discrimination 

 Credit Union Operations Updates 

• Section 1033 Proposed Rule requires financial institutions to establish commercially reasonable electronic interface to fulfill information requests. 

• Consumer Information Requests 

• Third-Party Information Requests 

• Updates to the Telephone Consumer Protection Act (TCPA) 

Watch the full video on InfoSight! 

CU PolicyPro Content Updates (January 2024) 

This update included 15 policy updates, many in response to annual threshold changes related to Regulation Z, consumer leasing, HSA Savings Account Contribution limits, HMDA asset size exemptions, and Regulation D reserve requirements. In addition, two new model procedures (Beneficial Ownership Information Access Procedures and Reconsideration of Value Procedures) were created.  

RecoveryPro Content Updates (November 2023) 

In response to NCUA feedback, Section 1510: Notification/Escalation was updated to include a statement that a Suspicious Activity Report (SAR) will be filed in situations of criminal activity related to a data compromise event, and a new section, 1560: Event/Incident Postmortem Activity was developed to serve as a formal framework for conducting a review and analysis following significant incidents or events. A Sample Event Incident Log was added to be used as part of the postmortem process to capture crucial details about each event. 

Additional details regarding each of these content updates can be found in the CU PolicyPro/RecoveryPro system in the Support area! 

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Whether you are a federal or state-chartered credit union, there are state laws that impact your operations. The most efficient and quickest way to find those laws is through InfoSight. This member benefit provides you with access to applicable state content for all 50 states, without you needing to search through tons of random online sources. Stop wasting time trying to research when InfoSight has aggregated all the information your credit union needs to stay compliant in an ever-changing and evolving federal and state environment. 

Whether you are a federal or state-chartered credit union, there are state laws that impact your operations. The most efficient and quickest way to find those laws is through InfoSight. This member benefit provides you with access to applicable state content for all 50 states, without you needing to search through tons of random online sources. Stop wasting time trying to research when InfoSight has aggregated all the information your credit union needs to stay compliant in an ever-changing and evolving federal and state environment. 

CFPB Blog: Beware of New CFPB Imposter Scams 

CFPB, and Seven State Attorneys General Sue Debt-Relief Enterprise, Strategic Financial Solutions, for Illegally Swindling More Than $100 Million from Financially Struggling Families 

Did Someone Tell You to Move or Transfer Your Money? It Could Be a Scam 

Protect Members From Job ‘Opportunities’ Fraud 

Feb. 12, 2024: Comments Due FRB Interchange Proposal 

Feb 20, 2024: Effective Date FinCEN BOI Access Rule 

Mar 11, 2024: Comments Due FTC Proposed COPPA Changes 

Apr 1, 2024: Comments Due CFPB Overdraft Rule 

May 27, 2024: Memorial Day – Federal Holiday 

What are the potential financial concerns that may be Red Flags of financial exploitation of a vulnerable adult? 

Financial exploitation of vulnerable adults may take on many different forms.  Here are some common concerns a member may mention that could potentially be Red Flags when it comes to vulnerable adults. 

• I have trouble paying bills because the bills are confusing to me. 

• I do not feel confident making big financial decisions alone. 

• I do not understand financial decisions that someone else is making for me. 

• I give loans or gifts more than I can afford. 

• My children or others are pressuring me to give them money. 

• People are calling me or mailing me asking for money, saying I won a lottery. 

• Someone is accessing my accounts or money seems to be disappearing. 

In addition, other things staff should be looking for include: 

• Significant withdrawals from the elder’s accounts. 

• Unusual bank account activity, such as withdrawals from automatic teller machines when the individual cannot get to the bank. 

• Signatures on checks and other documents that do not resemble the elder’s signature. 

• Checks or other documents signed when the elder cannot write or understand what he or she is signing. 

• Numerous new withdrawals, usually in round numbers ($50, $100, $1,000, $5,000, etc.) 

• Increased activity on credit cards 

• Withdrawals made from savings or CDs despite penalty assessments 

• Change in account beneficiaries 

• New (unfamiliar) authorized signers on accounts 

• Elder is confused about recent financial arrangements 

• Change in property title, quitclaim deed, or new or refinanced mortgage 

• Credit union statements no longer going to the elder’s home 

For your individualized login, select your state below. 

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, 

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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