Is Flood Insurance Required if a Flood Map Zone Changes?
Questions: Our life-of-loan flood zone monitoring vendor notified the credit union that a certain member’s property securing his mortgage loan is newly in a flood zone. Is flood insurance required even though there is not a “triggering” event (making, increasing, renewing, or extending a covered loan)? Our member is disputing the new flood zone determination […]
Does the July 1 Reg CC update require a change in terms notice?
Question: Hi Heather. Some questions. Do the upcoming dollar threshold changes to funds availability schedules under Regulation CC require the credit union to provide a change in terms notice to affected members? And if so, is there model change in terms language? Answer: What is Changing? Let’s start out by explaining what is changing. Regulation […]
Reporting Loan Servicer Identity to FEMA
Question: Hi Heather, Our NCUA examiner asked us how we report loans with flood insurance to the FEMA administrator. I wasn’t aware of this requirement, and I couldn’t find any information on FEMA’s website about how to exactly do this. Can you help? Answer: I can help! Let’s start with the requirement from NCUA flood […]
CTR with “unknown” transactor?
Question: Hi Heather, Hoping I could ask your advice on a fraud issue we had yesterday. Someone impersonating our member withdrew cash at two of our offices that totaled more than $10,000. My question is how should I complete CTR since we know it wasn’t our member? Can I say “unknown” for everything? Answer: Wowza. […]
Who needs to be listed on a CTR?
Question: If a Currency Transaction Report (CTR) reportable cash transaction happens on a joint account, does the CTR need to include the names of all joint owners, or only the member who conducted the transaction? I suspect we need to include all joint owners and check Box 2c “Person on whose behalf transaction was conducted” […]
Did Beneficial Ownership Certification Rules Change?
Question: Do you have any guidance on this article released by the Financial Crimes Enforcement Network (FinCEN)? Do credit unions still need to collect beneficial ownership information from business members? Or do we only collect information for “reporting companies” as defined by the new rule? Answer: Great Question! credit unions must still collect beneficial ownership […]
Does the new CFPB Payday Lending Rule Apply to your Credit Union?
Question: Hi Heather. I feel like I am late to the game here, because I am just hearing about the CFPB Payday Lending Rule. I am trying to understand how this will affect our credit union. I’m especially concerned because the credit union offers longer-term balloon payment, closed-end loans for RVs. If we offer refinance […]
Private Education Loans
Question: Hi Heather, My board has asked me to look into student loans. Can we even do it? How would I write a great Policy for this that makes the NCUA happy? Great Question! Many credit unions try to avoid making inadvertent private education (PE) loans. They aren’t incredibly difficult, they just require specific disclosures that some CUs […]
Overdraft Lines of Credit: Requiring Joint Checking Account Owner to be a Joint Borrower
Question: Good Morning Heather, Let’s say a member with a checking account is applying for an overdraft line of credit (LOC) for that checking account. If the checking account is jointly owned, can we require both owners be liable on the overdraft LOC? Great Question! Yes you can. Usually, Reg B prohibits a creditor from […]
