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 […]
Threats to fee income continue
Threats to fee income continue During the last few months, we have noted growing pressure on financial institutions from multiple fronts to regulate, reduce or eliminate fee income generated from overdrafts and non-sufficient funds (NSF) fees. The emerging threat to non-interest income was a roundtable discussion topic at our 2022 Executive Summit in May. Regulatory […]
Risk Based Pricing Notices on Business Purpose Loans
Risk Based Pricing Notices on Business Purpose Loans Question: Are risk-based pricing notices (RBPN) required on business purpose loans? Answer: No. RBPN’s are on required “in connection with an application for, or a grant, extension, or other provision of, credit to a consumer that is primarily for personal, family, or household purposes.” More info at: https://www.consumerfinance.gov/rules-policy/regulations/1022/70/ Back […]
What does NCUA going to CAMELS mean?
What does NCUA going to CAMELS mean? Effective in April of this year, NCUA will switch its exam framework from CAMEL to CAMELS. This means that interest rate risk sensitivity will be measured separately from liquidity. Sensitivity to interest rates is the new S. Until now, it has been examined as part of the L—liquidity. […]
Providing Mortgage Disclosures on a Denial
Providing Mortgage Disclosures on a Denial Q. Good morning Heather, I feel like this is a silly question – but I want to clarify it. If we receive a mortgage application with the six pieces of information from a borrower that constitutes an application under Reg Z and triggers the need to send a Loan Estimate – if […]
