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 […]
Lending to Minors
Lending to minors Q. Can we do loans for people under 18? I have never heard of it but apparently the credit union has made loans for members under 18 in the past. A. Great Question! There are no prohibitions regarding making a loan to a minor, however, in Utah the contract will be unenforceable until the […]
Ovedraft Opt-In for Recurring Debit Card Transactions
Overdraft Opt-In for Recurring Debit Card Transactions Q. Heather, What does Reg E say regarding recurring debit card transactions? We have a member that opted out of overdraft coverage, but our system is still charging his monthly cell phone and newspaper subscription and charging him courtesy pay fees when these transaction overdraw his account. We found […]
Got BSA Training?
Got BSA Training? We understand mandatory Bank Secrecy Act (BSA) training can get old, stale, annoying, difficult, etc. To that end, the Utah Credit Union Association would like to introduce lots of BSA training resources for 2022. Online Training Our online training consists of recorded webinars that can be viewed and class materials that can […]
Compliance Essentials
Compliance training Some of you may already know that we are conducting our annual compliance training series a bit differently this year. While making plans for 2022, Liz White (our Director of Education and Training) and I discussed some objectives: After 18 months of online training, we wanted to get back to having compliance classes […]
Holiday counting and Reg Z
Holiday counting and Reg Z Federal Holidays that fall on a weekend (like Christmas and New Year’s Day do this year) always bring up questions with how financial institutions count days for various Regulation Z requirements. You may know that Regulation Z famously has TWO definitions for business day. The “Business Day” definition you use depends […]
