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Compliance Update with Amy K

4/20/2023

 
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An IRA Update webinar; CFPB issues revised methodology for average prime offer rates; recorded version of CECL webinar available now; and more. 
by Amy Kleinschmit, Chief Compliance Officer 
 
IRA Update Webinar
Join us on Wednesday, May 3 at 9:00 a.m. (CT) to learn about the latest updates on IRA (Secure Act 2.0). This webinar will build on your knowledge of IRA basics to address some of the more complex IRA issues your credit union may handle. This course includes how the transitions rules work, RMDs and death distributions. We will also discuss amending documents.

Our speaker is Matthew Dickinson, who uses real-world exercises to help participants apply information to job-related situations. Mr. Dickinson has over 18 years in Banking and retirement and has held many titles within his career. He has worked for companies such as Ascensus, Merril Lynch, Wells Fargo, and Frandsen. On a day-to-day basis, Matt helps financial institutions gain and maintain their knowledge base to manage their IRA portfolio.

Webinar Highlights include:
  • Death distribution options; how SECURE changed some of the options but how we still use some of the old beneficiary options.
  • Creating inherited IRA accounts.
  • Reporting to IRS in the “year of death” and then “year after death.”
  • When and how to use the “W-4R” in 2023 and what happens to the “W-4P.”
  • Review RMD rules and characteristics.
  • Getting ready for year end and what happens in January: Fair Market Statements, RMD Notices and 1099-Rs.
  • Life expectancy tables for 2023 RMD calculations and inherited IRA RMD calculations change
  • Amendment and plan agreement update.
  • RMD age now 73.
  • Legislative update – SECURE 2.0 updates.

Special pricing of only $129 has been secured for our affiliated credit unions for this 3 hour training event.
Register today.  

Average Prime Offer Rate

The Consumer Financial Protection Bureau (CFPB) recently issued a revised version of its “Methodology for Determining Average Prime Offer Rates.”

Under the current methodology, the CFPB uses pricing data from the Freddie Mac Primary Mortgage Market Survey® (PMMS) on three products—30-year fixed-rate mortgage; 15-year fixed-rate mortgage; and five-year variable-rate mortgage—and pricing data from CFPB’s own internal survey on one-year variable-rate mortgages. Per the CFPB, Freddie Mac is changing the public version of PMMS to no longer include points, fees, and adjustable rates data. In response to the unavailability of certain data previously relied on to calculate APORs, the CFPB has determined that data from Intercontinental Exchange Mortgage Technology (ICE Mortgage Technology) is the most suitable option to replace PMMS.

The CFPB has updated the FFIEC’s website to note this change in the source of survey data and published a revised methodology statement that reflects corresponding changes in the methodology. The CFPB will begin using ICE Mortgage Technology data and the revised methodology to calculate APORs on or after April 21, 2023. Survey data used to calculate APORs will continue to be posted on the FFIEC’s website every week at https://ffiec.cfpb.gov/tools/rate-spread.

ACH Operation Bulletin

NACHA issued ACH Operation Bulletin #1-2023, found here. This updates the sample Written Statement of Unauthorized Debit (WSUD) to include language alerting consumers of the risks of making false claims of unauthorized ACH debits to their financial institutions.

Per the Bulletin – “In an effort to educate consumers, and as an anti-fraud measure, Nacha is amending its sample form WSUD to include a disclosure, similar to those found on other widely used banking forms, informing consumers of the possible penalties that could result from making false representations to a financial institution. Nacha’s goal is to alert well-meaning consumers to federal laws and help them avoid violating such laws, based on misguided advice they may have received.”

CECL Webinar – In case you missed it!
Earlier this week, DakCU was happy to host a complimentary webinar to review the NCUA Simplified CECL Tool. This tool provides a methodology for credit unions to determine the Allowance for Credit Losses (ACL) on loans and leases for their loan portfolio.
 
Our guest speaker was Chris McGrath, Acting Chief Accountant, for the National Credit Union Administration, Office of Examination and Insurance, and fielded a number of questions from our attendees.
 
As the NCUA’s Acting Chief Accountant, McGrath serves the credit union industry with advice and guidance on the application of generally accepted accounting principles.  Prior to joining NCUA in 2004, McGrath practiced in financial auditing and assurance with Deloitte & Touche, including three years working out of Istanbul, Turkey, auditing multinational companies under U.S. GAAP and International Financial Reporting Standards.  For NCUA, he has served as its Budget Officer as well as leading financial reporting on its Share Insurance Fund. McGrath is a Certified Public Accountant licensed in Maryland and Virginia.  For over 15 years, McGrath has been an adjunct professor at Georgetown University teaching accounting, finance, and economics.
 
If you missed the live webinar and would like to review the recording please email Amy Kleinschmit at [email protected] for the link which will be available for 30 days.

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