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Compliance Specific News & Resources for GoWest Credit Unions
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Compliance Newsletter

COMPLIANCE HEADLINES

National Credit Union Administration (NCUA) 


NCUA Releases Q4 2023 State-Level Credit Union Data Report 


The NCUA released the latest Quarterly U.S. Map Review which shows that federally insured credit unions experienced growth in loans and the share of credit unions with positive net income increased over the year ending in the fourth quarter of 2023, while delinquencies rose, and assets and shares and deposits declined. 


Nationally, assets among federally insured credit unions declined 1.5 percent at the median, and shares and deposits declined 3.0 percent over the year ending in the fourth quarter of 2023. Loans outstanding rose by 6.2 percent at the median over the year ending in the fourth quarter of 2023. The median total delinquency rate at the end of 2023 was 61 basis points, compared with 48 basis points at the end of 2022. Additionally, 87 percent of federally insured credit unions had positive year-to-date net income in the fourth quarter of 2023, compared with 85 percent in the fourth quarter of 2022. 


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Consumer Financial Protection Bureau (CFPB) 


2023 HMDA Modified LAR Availability 


The CFPB announced that the 2023 HDMA modified loan/application registers (LARs) are now available for each institution that filed HMDA data collected in 2023. The modified LARs provide each financial institution's loan-level HMDA data, as modified to protect applicant and borrower privacy in accordance with the Consumer Financial Protection Bureau’s final policy guidance on the disclosure of HMDA data. Users also have the ability to download one combined file that contains all institutions’ modified LAR data. 

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NACHA 


New Nacha Rules Take Aim at Credit-Push Fraud 


NACHA members approved a set of rules intended to reduce the incidence of frauds, such as business email compromise (BEC), that make use of credit-push payments. The new rules establish a base-level of ACH payment monitoring on all parties in the ACH Network (except consumers). While the new rules do not shift the liability for ACH payments, for the first time receiving financial institutions (RDFIs) will have a defined role in monitoring the ACH payments they receive. 


The new rules follow the flow of a credit-push payment to promote the detection of fraud from the point of origination through the point of receipt at an account at the RDFI. When fraud is detected, the rules empower the originating financial institution (ODFI) to request the return of the payment for any reason; the RDFI to delay funds availability (within the limits of Regulation CC) to examine the payment more closely; and the RDFI to return a suspicious transaction on its own initiative without waiting for a request or a customer claim. An additional rule facilitates transaction monitoring by RDFIs by applying a standard transaction description for ACH credits used for payroll payments. 



League InfoSight Highlight

League InfoSight Highlight: We are Here to Help! 


Whether it’s technical or content related, the area of regulatory compliance can prompt many questions. League InfoSight is always happy to hear from you and to provide you and your team with guidance and resources! 

Check out this FAQ – this is the number one question our team gets asked: 

Which policies require board approval?  

  

There is a lot of subjectivity around policies and the associated review schedule. The NCUA Examiner's Guide recommends an annual review cycle for all "major" policies. Unfortunately, there isn't any guidance as to what policies the NCUA believes to be "major." Therefore, a conservative approach is for the credit union to have the board review all policies annually unless the credit union has conducted an appropriate analysis to make the determination of what policies may be considered "major." 

  

The Resources area in CU PolicyPro includes a Policy List with Guidelines document which identifies policies found in CU PolicyPro that are mandatory based on regulation. We would recommend that “mandatory” policies at a minimum are included as “major” policies and are reviewed annually by the Board. 

We are ready to answer your questions! Please contact our staff with feedback or inquiries at info@leagueinfosight.com. We look forward to hearing from you! 


Mary Ann Koelzer,
Senior Technology Products Manager, League InfoSight 




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. 



ARTICLES OF INTEREST

FinCEN Publishes an Administrative Ruling Regarding CIP-COD Requirements for Designated Beneficiaries of IRAs 


NCUA Releases 2023 Annual Report 


No FEAR Act Annual Report for Fiscal Year 2023 


CFPB Joins Federal and State Agencies in Coordinated Statements on Tech & Enforcement 


SCAM UPDATES

Did Someone Send You to a Bitcoin ATM? It’s a Scam 


How to Spot Hard-to-Spot Rental Scams 



COMPLIANCE CALENDAR

 Apr 1, 2024:  Comments Due CFPB Overdraft Rule 


Apr 4, 2024: NCUA Liquidity Risk Management Webinar 


Apr 11, 2024:  NCUA “Money Moves to Build Savings and Financial Capability” Webinar 


Apr. 30, 2024: 5300 Call Report Due 


May 12, 2024: FRB Interchange Fee Proposal Comments Due 


May 27, 2024: Memorial Day – Federal Holiday 


TOOLS & RESOURCES

Effective Dates
Bulletins & Alerts
Webinar Calendar
AffirmX and GoWest Partnership

Q&A OF THE WEEK

A member has come into the credit union to speak with a collections officer. The door to the office is closed and the voices are getting louder and meaner. What should we do? 


If the credit union has a security officer, you may want to consider sending her in to intervene.  If there is obvious escalation and possibly leading to physical violence, someone at the credit union should call the police immediately.  It might be a good idea to develop a policy to cover personal safety of staff.  Many institutions have two Collections officers present in any meeting with a member.  A coding system can be developed when any staff member fears for his/her safety.  For example, the staff member in question might call the Head Teller and ask for "the blue file" knowing that the credit union does not use files that are blue in color.  Or the staff may page for "Mr. Armstrong," the branch manager. 

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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