2012 Third Quarter Compliance and Regulatory Issue Review.

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Presentation transcript:

2012 Third Quarter Compliance and Regulatory Issue Review

Overview of 3 rd Quarter Compliance Issues Bank Secrecy Act – Electronic Filing/New Formats FCC Telemarketing Rules NCUA – Interest Rate Risk NCUA – Troubled Debt Restructuring

BSA E-Filing Guidance Electronic filing required by July 1, 2012 New CTR and SAR formats CTR filing within 15 days – required by March 31, 2013 SAR continued activity filing clarification For additional information: And CUBE TV:

FCC’s Telemarketing Rules Opt-out must be provided for prerecorded telemarketing calls For additional information: And:

Interest Rate Risk Policy & Program NCUA Letter to Credit Unions 12-CU-05 Comprehensive IRR written policy; Accountable oversight by the Board and management; Measurement and monitoring systems; Internal controls; and Decisions based on IRR measurement results. For additional information: And CUBE TV:

TDRs - Loan Workouts – Nonaccrual NCUA – 12 CFR Troubled Debt Restructuring and Loan Workout and Nonaccrual Policy  Relaxed reporting requirements  New written loan workout policies  Loans over 90 days past due must be on nonaccrual For information on TDR’s: And CUBE TV:

Fourth Quarter Compliance Issues Required reviews and audits  ACH  S.A.F.E. Act Unlimited share insurance for non-interest bearing accounts expires For information on Share Insurance:

CFPB Focus as of June 2012: For additional information: comment/ comment/ And: of-regulatory-priorities/ of-regulatory-priorities/ Electronic fund transfers RESPA Equal Credit Opportunity Act Fair Credit Reporting Privacy of consumer financial information Truth in Savings & Lending S.A.F.E. Act Home Mortgage Disclosure Act Fair debt collection practices Private education lending Pre-dispute Arbitration Overdraft programs Prepaid cards Elder Abuse CFPB

NCUA Pending Changes Information on Fleet: Information on Reg. Relief: Fleet Vehicle definition amended – 5 Newly Proposed Rules for Regulatory Relief  “Small Entity” – from $10M to $30M  Rural District Definition  Variable-rate TIPS Investments  Payday Alternative Lending

Thank you for joining me for this 3 nd Quarter Review of compliance issues important for your credit union!