Compliance Blog

By: Joni Senkpeil, SVP, Member Solutions Are you unsure where to start with regulatory training requirements? Click here for a reference guide to quickly verify which tasks require training and how often. ICUL offers several training options: LIVE Regional Director-led training on a variety of topics FREE On Demand programming on certain topics Webinar based training through our partner, Credit Union ...

By: Kari Osier, Compliance Specialist Technically titled the Secure and Fair Enforcement for Mortgage Licensing Act of 2008, the S.A.F.E. Act was created to establish minimum standards for licensing and regulation of mortgage loan originators (MLOs) to enhance consumer protection and reduce fraud. What are the registration requirements?Individual residential MLOs employed by agency-regulated institutions, which includes credit unions, ...

By: Shannon Basile, Director of Compliance On June 22, 2022 the Financial Crimes Enforcement Network (FinCEN) released guidance on how to apply customer due diligence rules to independent ATM owners or operators.  The purpose of this guidance is to ensure independent ATM owners or operators, who provide critical financial services to persons in underserved areas, have ...

By: Kari Osier, Compliance Specialist Lately I’ve been working on refreshing my memory on the TRID Rule. One question that has come up occasionally is whether or not the Loan Estimate or Closing Disclosure must be signed by the consumer once it has been received. Normally this would require reading the regulation and commentary but the ...

By: Shannon Basile, Director of Compliance In recent weeks, I’ve received some questions about how to respond to a judgment or subpoena issued in another state.  This issue was highlighted in a recent Consumer Financial Protection Bureau (CFPB) enforcement action against Bank of America (BOA), regarding the bank’s process for handling foreign garnishments. The CFPB consent ...

Illinois Secure Choice: Expanding Retirement Savings Access for Illinois Workers – Additional Compliance Responsibility for Smaller Credit Unions Launched in 2018, Illinois Secure Choice is a retirement savings program that makes it easy for employees to save at work. In 2021, the State Treasurer initiated legislation to expand the scope of the program to apply to smaller ...

By: Kari Osier, Compliance Specialist Since the California Consumer Privacy Act (CCPA) was passed into law, four other states have passed comprehensive data privacy laws. Virginia Consumer Data Protection ActThe Virginia law contains many elements of California’s CCPA and Europe’s data privacy law (GDPR), and will go into effect on January 1, 2023. The CDPA includes language to ...

By: Shannon Basile, Director of Compliance The Social Security Administration (SSA) created the Representative Payment Program to provide benefit payment management for beneficiaries who are not capable of managing their own Supplemental Security Income (SSI) payments.  Typically, the SSA will look for family or friends to serve as the beneficiary’s payee.  If no family or friends ...

HIGHLIGHTS DOJ Issues ADA Guidance on Website AccessibilityCFPB Issues Advisory Opinion on Fair Lending LawsNCUA and Other Agencies Release Revised Guidance on Interagency Questions and Answers Regarding Flood Insurance DOJ Issues ADA Guidance on Website Accessibility Recently, the Department of Justice (DOJ) issued guidance on website accessibility under Title III of the Americans with Disabilities Act (ADA), ...

By: Patrick Smith, SVP, Regulatory Affairs I have been receiving a number of calls from credit unions regarding the challenges in the current auto lending environment.  For Illinois state-chartered credit unions, the problem is amplified given the somewhat restrictive and rigid consumer lending limit authority set forth in Section 190.160 of the Illinois Department of Financial and Professional ...