What is Considered an Application for HMDA?
Question: Hi Heather, Quick question… We helped a member earlier this year with a reduction of his HELOC interest rate. An application was completed to ensure that he qualified for the reduction, but a new loan was not completed in our host system. Do we need to submit a HMDA filing for this application? Answer: […]
Advertising Certificate Rates
Question: Hey Heather. Our credit union is going to offer a limited time CD promo to bring some money in. We have an outside reader board that we have used in the past for marketing, but we’ve never advertised rates. I don’t want to be out of compliance, but if are going to offer a […]
What’s the Deal with Reg U?
Question: Hi Heather. I would like your opinion on Regulation U. The way I read it Reg U states any loan secured by stocks would have additional reporting requirements. But some others at my credit union think it means that the reporting is only required if stock is purchased and then used as collateral, but […]
Flipping tables and disputing findings
On December 5, Scott Simpson and I joined league professionals from other NCUA Western Region states to meet with the Western Region Director, Cherie Freed, and several of her top staff members. The meeting is an annual tradition, and over the years we’ve developed a cordial rapport with Cherie. She and her team members are […]
Junk fees were the least important thing Pres. Biden mentioned today in his press conference
Today President Biden held a press conference in which he vowed that the Federal government would help middle class American’s by outlawing junk fees. He cast a broad net, which encompassed credit unions. From the official press information: The CFPB is taking action to require large banks and credit unions to provide basic information to […]
CUs distribute wealth more evenly than banks
I’ve already posted other thoughts from reading Secrets of the Temple, a decidedly left-leaning book. One last note. A notion referred to several times in the book is that banking, generally, distributes wealth up the economic ladder—a point that’s difficult to disagree with. It goes like this: The wealthy deposit their excess funds into a financial […]
Thoughts after reading “Secrets of the Temple: How the Federal Reserve Runs the Country”
As I edited Lynn Kuehne’s book early last year, his numerous references to the book Secrets of the Temple, by William Greider, led me to read the book. I thought I’d offer up some observations after reading the 700-page monster. Overview The book chronicles the late 1970s and early 1980s, when the Federal Reserve pushed […]
New Account Check Holds When Adding an Additional Depositor to an Existing Checking Account
Question: Regarding Reg CC and check holds, can we apply a new account exception hold on an established account when a new account holder is added? Answer: Interestingly enough, yes. Here is the commentary from 12 CFR 229.13(a) (1)(b)(vi): If two customers that each have an established individual account with the bank open a joint […]
Is Compliance Ready for AI?
Is anyone else fascinating by ChatGPT and other natural language AI chatbot’s? Maybe you’re wondering if this new piece of technology can help you with your job as a compliance professional. Maybe you’re worried that AI technology will make compliance professionals obsolete. I wanted to see what ChatGPT could do if it replaced me at the […]
