Compliance Update with Amy K
by Amy Kleinschmit, Chief Compliance Officer
Flood Insurance Q&A Updated
Five federal regulatory agencies recently issued revised questions and answers (Q&As) regarding federal flood insurance law and the agencies’ implementing regulations. These Q&As replace those originally published by the agencies in 2009 and 2011 and consolidate Q&As proposed by the agencies in 2020 and 2021.
Significant topics addressed by the revisions include guidance related to major amendments to the flood insurance laws with regard to the escrow of flood insurance premiums, the detached structure exemption, force placement procedures, and the acceptance of flood insurance policies issued by private insurers.
In addition, the agencies reorganized the Q&As by topic to make it easier for users to find and review information related to flood insurance.
The updated Flood Insurance Q&As can be found here. The Q&A begins on page 153 of the document at the preceding link. However, to assist in finding the prior Q&A from 2009 and 2011 the agencies included a redesignation table that starts on page 147.
The Q&A is broken out in the following categories –
The National Credit Union Administration will be hosting a free 90-minute webinar on June 2 with the Community Development Financial Institutions Fund.
NCUA Chairman Todd M. Harper will deliver opening remarks and staff from both agencies will discuss Community Development Revolving Loan Fund grants, the CDFI Fund’s Small Dollar Loan Program, and other opportunities to help eligible credit unions make investments in their communities.
Online registration for the webinar is now open.
CFPB Advisory Opinion
The Consumer Financial Protection Bureau (CFPB) recently issued an advisory opinion, found here regarding the Equal Credit Opportunity Act, as implemented by Regulation B.
The CFPB issued this Advisory Opinion to “affirm that the Equal Credit Opportunity Act (ECOA) and Regulation B protect both those actively seeking credit and those who sought and have received credit.”
As explained by the CFPB, ECOA and Regulation B plainly apply to circumstances that take place after an extension of credit has been granted, including a revocation of credit or an unfavorable change in the terms of a credit arrangement. Furthermore, creditors are required to provide notifications that include a statement of the specific reasons for the adverse action taken or disclose an applicant’s right to such a statement.
The Advisory Opinion further details that “Reading ‘applicant’ to protect individuals and businesses from discrimination both during the process of requesting credit and once credit has been extended furthers ECOA’s purpose. It prevents a creditor from canceling an existing account because of a borrower’s race. It bars a creditor from unfavorably modifying the terms of an existing account—perhaps by lowering the amount available on a line of credit—because of a borrower’s national origin. It stops a creditor from requiring women with existing accounts to reapply for their credit upon getting married. And it ensures that a creditor would be required to provide a statement of reasons to the applicant in any of these situations.”
This advisory opinion is an interpretive rule issued under the CFPB’s authority to interpret ECOA and Regulation B, including under section 1022(b)(1) of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which authorized guidance as may be necessary or appropriate to enable the Bureau to administer and carry out the purposes and objectives of Federal consumer financial laws. As an interpretive rule, this rule is exempt from the notice-and-comment rulemaking requirements of the Administrative Procedure Act.
CU Policy Pro Updates
There have been a number of technical enhancements that were released in CU PolicyPro this month. These enhancements were the direct result of client feedback, so please continue to send your recommendations and wish lists for future updates!
Based on multiple user requests, the Assignments area has been updated with the following features:
In the Multi-Policy Functions tab, a new option for Delete Policies has been added.
New Structure and Numbering Options
To provide greater flexibility in structuring your CU Policies, you can now create multiple levels of content, rather than the previous two-level structure (Chapter > Policy). You can also number the content using alpha, numeric, and dashes and periods. For instance, 1001-1, 1001A, 1001.32, R2D2, etc. are all OK.
Another new feature is the addition of a Content Label, which allows you to determine how any section will be named. Instead of being limited to the Chapter and Policy labels, you can now choose your own labels such as Procedure, Appendix, Methodology, etc. You can also choose to have no label. To help you easily update your label preferences, there is a new Multi-Policy Function where you can choose multiple sections and update the content label all at one time.
Learn more here.
As always, DakCU members may contact Amy Kleinschmit with any compliance related questions.
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