1. NCUA Consumer Compliance
Lisa Roberson, Program Officer
Office of Consumer Financial Protection and Access
NCUA Consumer Compliance
GA CU Compliance Council Meeting
Atlanta, Georgia
March 14, 2017
The information contained in this presentation is for informational purposes only. It expresses the views and opinions of NCUA staff and is not binding on NCUA or NCUA Board Members. The presentation and participation by the presenter does not constitute an endorsement by the presenter or NCUA of the Georgia Credit Union Affiliates or its products or services. The comments are of the presenter’s and not an official legal opinion of NCUA.

2. NCUA Consumer Compliance
Office of Consumer Financial Protection & Access (OCFPA)
Office of Examination & Insurance (E&I)
NCUA Regional Offices (ROs)
Office of primary interest for consumer financial protection policy, rulemaking, guidance & training
Fair lending examinations
Interagency consumer compliance coordination
NCUA Consumer Assistance Center
Overall examination policy and guidance
Examination tools and resources
Bank Secrecy Act (BSA) / Anti Money Laundering (AML)
Flood Disaster Protection Act (FDPA)
SAFE Act
Consumer compliance reviews during examinations
Consumer compliance subject matter examiners
Consumer Compliance March 2017

3. Consumer Compliance Rating System
FFIEC Uniform Interagency Consumer Compliance Rating System
(CC Rating System)
Published - November 7, 2016
Effective Date - March 31, 2017
CC Rating System Final Guidance
NCUA is planning to release guidance on the updated rating system.
Consumer Compliance March 2017

4. Consumer Compliance Rating System
NCUA and Current CC Rating System
NCUA does not issue a separate CC Rating
NCUA integrates the principals and standards into the current CAMEL structure
NCUA assesses a CU’s ability to manage Compliance Risk and reflects that in the “M” component overall CAMEL rating
NCUA’s practice is not changing
Consumer Compliance March 2017

5. Consumer Compliance Rating System
FFIEC’s CC Rating System is designed to be
Risk-Focused
Transparent
Actionable
Incent Compliance
Consumer Compliance March 2017

6. Consumer Compliance Rating System
Emphasizes Compliance Management Systems (CMS)
Board and Management Oversight*
Compliance Program*
Violations of Laws and Consumer Harm
*Consideration given to size, complexity, and risk profile, but all credit unions should maintain effective CMS.
Consumer Compliance March 2017

7. Consumer Compliance Rating System
Compliance Risk Indicators
Board and Management Oversight
Commitment to CMS
Change Management Processes
Risk Management of Products, Services, and Activities
Self-identification Efforts and Corrective Action
Consumer Compliance March 2017

8. Consumer Compliance Rating System
Compliance Risk Indicators
Compliance Program
Effectiveness of CMS
Policies and Procedures
Training
Monitoring and Audit Programs
Complaint Resolution
Consumer Compliance March 2017

9. Consumer Compliance Rating System
Compliance Risk Indicators
Violations of Laws and Consumer Harm
Root Cause of the Violation
Severity of Consumer Harm
Duration of the Violation
Pervasiveness of the Violation
Consumer Compliance March 2017

10. 2017 Supervisory Priorities
NCUA guidance intended to assist credit unions in preparing for the next examination
Letter to Federally Insured Credit Unions 17-CU-01
Top areas of supervisory focus include:
Cybersecurity Assessment
Bank Secrecy Act Compliance
Internal Controls and Fraud Prevention
Interest Rate and Liquidity Risk
Commercial Lending
Consumer Compliance
NCUA Consumer Compliance Reviews

11. 2017 Supervisory Priorities
CONSUMER COMPLIANCE
Military Lending Act
Regulatory Alert 15-RA-04, Announcing Amendments to MLA Regulation (October 2015)
Regulatory Alert 16-RA-04, Complying with Changes to MLA (March 2016)
Regulatory Alert 16-RA-06, MLA – DoD’s Interpretive Guidance (September 2016)
Servicemembers Civil Relief Act
Consumer Compliance April 2017

12. Consumer Compliance Resources
compliance/resource-centers/consumer.aspx
Consumer Compliance April 2017

13. Consumer Assistance Center
Responsible for addressing consumer complaints involving federal credit unions (FCUs) with total assets up to $10 billion, and in certain instances, federally insured state- chartered credit unions (FISCUs).
The Consumer Assistance Center receives complaints online and by fax and regular mail.
NCUA’s consumer protection website, MyCreditUnion.gov, hosts the online Consumer Assistance Center and provides access to complaint forms and information about the Consumer Assistance Center’s complaint handling process.
Consumer Compliance April 2017

14. Consumer Assistance Center - Online Portal
The portal was created to assist credit unions with:
Receiving correspondence from the NCUA Consumer Assistance Center about complaints concerning their credit union
Sending responses and complaint information
Checking the status of complaints filed with the NCUA Consumer Assistance Center concerning their institutions
Consumer Compliance April 2017

15. Financial Literacy Questions for you:
Are any of your credit unions doing Payday Alternative Loans (PALs)?
Do you offer Youth Savings Programs?
FFIEC Guidance to Encourage Financial Institutions' Youth Savings Programs and FAQs
NCUA Report: Financial Literacy and Financial Well-Being
NCUA Consumer Compliance Reviews

16. Financial Literacy Questions for you:
What NCUA Financial Literacy resources have been most helpful to you?
What else would you like to see?
NCUA Consumer Compliance Reviews

17. Reporting Financial Ed Programs
CU Profile Form - Credit Unions are Encouraged to Report all Financial Education Programs Have you tried In-School Branches?
NCUA Consumer Compliance Reviews

18. OCFPA Contact Information
Questions or Comments
Lisa Roberson
(703)
Consumer Compliance April 2017