Post on 18-Jan-2016
Compliance Outlook
2013 Second Quarter -
Third Quarter
Program Overview
Third Quarter 2013
• FTC – COPPA
• NACHA - Operating Rules Change
• NCUA – Loan Participations
Program Overview
Forth Quarter 2013
• CFPB – International Remittance Transfers
• CFPB – Credit Access Rule
FTC - COPPA 7/1/2013COPPA Requires:• Online privacy policy;• Notice to parents;• Parental consenting to information collection and
use;• Parental access to their child’s personal
information;• Parents can prevent further use or collection of
information;• Maintain the confidentiality, security, and integrity
of information; and• Retain personal information collected online from
a child for only as long as is needed for the purpose it was collected.
NACHA - Rules 9/20/2013Operating Rules Change:
• Health Care Payments
• ACH Security Framework
• Notifications of Change for Single Entries
• Stop Payments
NCUA – Loan Participations
7/25/2013
Loan Participation Requirements Amended:
• Purchasing credit unions subject to a concentration limit of $5 million or 100% of net worth, whichever is greater;
• Originating federal credit union risk retention requirement is 10%; risk retention requirement for other originating organizations is 5%, consistent with the requirements under the Dodd-Frank;
• Federally insured credit unions may establish different underwriting standards for loan participations.
CFPB – International Remittance Transfers
• 100 IRT Exemption
• Disclosures
• Temporary Exceptions
International Remittance TransferDisclosures:
International Remittance TransferTemporary Exceptions:
• Applies to credit unions; • Credit Union may estimate the
applicable exchange rate, back-end fees and taxes, and total funds to be received.
• Exceptions are limited and temporary and will only be available for qualified transfers through July 21, 2015.
CFPB – Credit Access Rule
The credit access rule allows:
• Joint-account income as an asset on credit applications.
11/4/2013
Thank you for joining us for this overview of the Credit Union Compliance Connection. Stay
Tuned……..