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CUs should assess impact of Fed Reg CC amendments
ALEXANDRIA, Va. (11/25/09)--The National Credit Union Administration (NCUA) has urged federally insured credit unions to assess the impact that the Federal Reserve’s recent amendment to its Regulation CC could have on “their funds availability policies and schedules.” These credit unions should also notify their members of the changes, if required to do so, the NCUA added. However, the NCUA said that the Fed amendments should not impose an “additional burden” on credit unions. The Fed recently amended its routing number guide to next-day availability and local checks in Regulation CC to reflect recent changes in the Fed's check processing operations, and transferred its check processing operations from the head offices of the Federal Reserve Bank of Dallas and the Los Angeles branch of the Reserve Bank of San Francisco to the Federal Reserve Bank of Cleveland. The Fed has also provided advanced notice that its check-processing infrastructure will be consolidated into a single check-processing region early next year. In a separate regulatory release, The NCUA also addressed recent Fed changes to the minimum level of points and fees that designate when lenders must provide borrowers disclosures required by Section 32 of Regulation Z, Truth in Lending. While “very few” credit unions charge mortgage rates and fees as high as those cited under the Fed changes, and few credit union real estate loans “should require these additional disclosures,” NCUA Chairman Debbie Matz said that some risk-based loans may exceed the Fed’s yearly thresholds. According to the NCUA release, the minimum total fee and point threshold as of Jan. 1, 2010, will decrease from $583 to $579. Under section 32 of Reg Z, lenders would be required to provide borrowers with additional disclosures if the total amount of points and fees exceeds $579 or 8 percent of the loan amount, the NCUA release added. For the full NCUA regulatory alerts, use the resource links.
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