Mon, Dec 23, 2013
Washington, District Of Columbia
As credit unions prepare to comply with pending Consumer Financial Protection Bureau mortgage regulations, the Credit Union National Association continues to answer key questions: CUNA staff addressed one credit union's concern about semi-monthly payments, and provided general details on changes to mortgage loan originator (MLO) regulations and disclosure changes in this month's CompBlog Wrap-Up.
First, the credit union query: How can a credit union comply with the periodic statement requirements in the CFPB's Mortgage Servicing final rule if it permits members, as a courtesy, to make semi-monthly payments on certain mortgage loans?
The answer is simple: CUNA compliance staff noted that credit unions may still issue one monthly statement covering the entire month or may decide to issue statements that reflect the semi-monthly payments in situations where the legal obligation requires a monthly payment, but semi-monthly payments are permitted for the convenience of the member. More details, as spelled out in the rule itself, are provided in the Wrap-Up.
Up next, CUNA provides a refresher on MLO regulations: The Wrap-Up details how credit unions can determine whether potential loan originators are qualified for the job, and what credit unions can do to ensure that MLOs receive appropriate training in connection with offering closed-end consumer credit transactions secured by a dwelling.
Outlines of the CFPB's integrated Truth in Lending Act and Real Estate Settlement Procedures Act disclosures, which were released last month, are also included in the Wrap-Up.
The Wrap-Up also lays out five things credit unions must know about the homeownership counseling list requirement included in the new CFPB mortgage rules, and provides information on the National Credit Union Administration's new fixed assets rule and supervisory letter on enterprise risk management.
And, as it does every month, the CompBlogUp lists the upcoming effective dates of new regulations, important compliance articles and reports to read, as well as CUNA training programs.
For more of the CUNA CompBlog Wrap-Up, and other compliance gems, use this link. CompBlog Wrap-Up
Source: CUNAParameters for providing appropriate reporting to the financial institution's board of directors or senior management that enable periodic evaluation of the effectiveness of the social media program and whether the program is achieving its stated objectives.