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NCUA Reg Alerts remind of APR, CFPB compliance
WASHINGTON (1/27/14)--Compliance tips to help credit unions cope with new Consumer Financial Protection Bureau regulations are provided in a trio of recent National Credit Union Administration regulatory alerts.

The agency also confirmed the 18% interest rate cap for federal credit unions would be in effect for another year in a separate letter to federal credit unions (14-FCU-02).

The first alert, 14-RA-04, reminds credit unions that service mortgage loans that as of Jan. 10, they are required to comply with CFPB's new Real Estate Settlement Procedures Act (REPSA) Mortgage Servicing rule for certain mortgage loans.

The RESPA Mortgage Servicing rule addresses:
  • Force-placed insurance;
  • Error resolution and information requests;
  • General servicing policies, procedures, and requirements;
  • Early intervention with delinquent members;
  • Continuity of contact with delinquent members; and
  • Loss mitigation.
The NCUA alert also discusses exemptions from portions of the rule.

Regulatory alert 14-RA-05 addresses rules governing mortgage loan originator compensation. CFPB rules that became effective earlier this month regulate how compensation is paid to a loan originator in most closed-end mortgage transactions. The rules also address mandatory arbitration, the waiving of certain federal claims, and financing credit insurance premiums in closed-end mortgage transactions and open-end credit, including home equity lines of credit secured by a member's principal dwelling.

The most recently released regulatory alert, 14-RA-06, outlines which credit unions will need to collect and submit Home Mortgage Disclosure Act data associated with mortgage loan applications processed during 2014.

Credit unions that are required to submit HMDA data must:
  • Have held total assets in excess of $43 million as of Dec. 31, 2013;
  • Have had a home or branch office in a Metropolitan Statistical Area on Dec. 31, 2013; and
  • Have originated at least one home purchase loan or refinanced a home purchase loan secured by a first lien on a one-to-four-family dwelling in 2013.
Credit unions that meet these three criteria must collect HMDA data during calendar year 2014 and submit the data to the Federal Reserve Board no later than March 2, 2015, the NCUA said.

For all three NCUA alerts and the letter to federal credit unions, use the resource links.
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