Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC

By: Credit Union Exam Solutions Inc.
  • Summary

  • This podcast provides you the ability to listen to new regulatory guidance issued by the National Credit Union Administration, and occasionally the F D I C, the O C C, the F F I E C, or the C F P B. We will focus on new and material agency guidance, and historically important and still active guidance from past years that NCUA cites in examinations or conversations. This podcast is educational only and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated. We also have another podcast called With Flying Colors where we provide tips for achieving success with the N C U A examination process and discuss hot topics that impact your credit union.
    2023
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Episodes
  • Statement of CFPB Director Rohit Chopra, Member, FDIC Board Member, on Stopping Fintech Deposit Meltdowns
    Oct 1 2024
    Hello, this is Samantha Shares. This episode covers the Statement of C F P B Director Rohit Chopra, Member, F D I C Board of Directors, on Stopping Fintech Deposit Meltdowns The following is an audio version of that statement. This podcast is educational and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and Forty years of National Credit Union Administration experience. We assist our clients with N C U A so they save time and money. If you are worried about a recent, upcoming or in process N C U A examination, reach out to learn how they can assist at Mark Treichel DOT COM. Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A. And now the statement. Statement of C F P B Director Rohit Chopra, Member, F D I C Board of Directors, on Stopping Fintech Deposit MeltdownsOver the past decade, we have seen a significant incursion into consumer deposit taking and payments activities by companies that aren’t banks or credit unions. These firms want the public benefits of being a bank or credit union, without the public obligations.This trend poses significant risks. We have developed a legal framework for banks over the past century designed to ensure people’s deposits are safe and that they have constant access to their funds. Deposit insurance and the special F D I C resolution process protect people if the bank fails and they retain quick access to their cash. When nonbanks engage in deposit taking, whether directly or in partnership with a bank, all these protections may not apply.Today, the F D I C Board of Directors is proposing a rule that would strengthen requirements for banks that partner with nonbanks in offering deposit-style products.This year, Synapse, a middleman between nonbanks offering deposit-style products to end users and their partner banks, filed for bankruptcy. The firm appears to have failed to properly track customer account balances and may have engaged in other shady practices. As a result, tens of thousands of customers have had their funds frozen for months. The banks have been unable to reconcile all the records necessary to get end users their funds back. This has led to severe harm, especially for people who were using the nonbank account as a primary checking or savings account.If one of the bank partners had failed, instead of Synapse, the horrible account balance tracking may have prevented the F D I C from making quick deposit insurance determinations and returning funds promptly to end users. When consumers do not have access to their funds, it can undermine confidence in the financial system and ruin lives.The proposed rule would require banks to maintain records identifying the ultimate end users, their balances, and other information for custodial accounts with transaction-style features. Banks would still be permitted to maintain these records through a third party as long as certain protections are in place, including daily reconciliations to make sure the numbers at the customer-level add up. Banks would also have to maintain constant access to the records, including in the event of the nonbank’s bankruptcy or other disruption. This framework would expedite an F D I C insurance determination if the bank fails and prevent the type of chaos we’re seeing with the Synapse bankruptcy if the nonbank fails.To be clear, this rule would not address all the risks posed by banking with a nonbank. Even if all the records are appropriately maintained, there still may be some delay in getting end users their money back as the nonbank’s bankruptcy proceeding plays out.1 In addition, nonbank deposit taking offered directly without a bank partner is generally outside the jurisdiction of the federal banking agencies.2 If the firm fails, consumers become unsecured creditors of the nonbank’s bankruptcy estate and may lose their funds.This proposal must not be the end of our collective work on this issue.First, disclosure requirements related to the intricacies of pass-through deposit insurance are woefully inadequate. Consumers should, at the very least, be told clearly and concisely that they could face delays or lose their money by banking with a nonbank.Second, we must continue to take enforcement actions against nonbanks that make misrepresentations about deposit insurance or misuse the F D I C name or logo.Finally, for nonbanks like Venmo, PayPal, and Cash App, that offer deposit-style products directly, state and federal policymakers should consider requiring these firms to promptly sweep people’s balances to their linked insured account automatically. Under their state licenses, these nonbank firms are supposed to be in the money movement business, not the banking business of keeping deposits. This concludes the C F P B Directors’ statement. If your Credit union could use assistance with your exam, reach out to ...
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    5 mins
  • The Future of Credit Unions: NCUA Vice Chairman's 2024 Vision
    Sep 24 2024

    # Show Notes: NCUA Vice Chairman Hauptman's 2024 ACU Congressional Caucus Remarks

    ## Key Points:

    1. Records Retention Policy Update
    - NCUA revising policies to limit required retention periods
    - Prompted by feedback from credit unions

    2. Overdraft and NSF Fees
    - Hauptman opposes forcing large credit unions to publicly state revenue from these fees
    - Warns against over-regulation potentially limiting financial access

    3. Technology and Innovation
    - NCUA exploring AI for fraud detection and customer service
    - Discussion on digital assets and stablecoins in credit union evolution

    ## Notable Quotes:

    - "The only people who think compliance is easy are those that don't have to do it."
    - "America's more than 140 million credit union members know their lives better than we do."
    - "My true north is making sure credit unions don't go the way of Blockbuster video because their regulator wouldn't let them compete."

    ## Context:
    - Speech delivered on September 9, 2024
    - Hauptman's term on the NCUA Board ends in August 2025

    ## Call to Action:
    For assistance with NCUA exams, contact Mark Treichel at marktreichel.com or on LinkedIn.

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    9 mins
  • FED Chairman Powell Cuts Rates 50BP: His Words on Why
    Sep 19 2024
    Hello, this is Samantha Shares. This episode covers Transcript of Chair Powell’s Press Conference Opening Statement September 18, 2024 The following is an audio version of that transcript. This podcast is educational and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and Forty years of National Credit Union Administration experience. We assist our clients with N C U A so they save time and money. If you are worried about a recent, upcoming or in process N C U A examination, reach out to learn how they can assist at Mark Treichel DOT COM. Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A. And now Chairman Powell’s opening statement. Transcript of Chair Powell’s Press Conference Opening Statement September 18, 2024 CHAIR POWELL. Good afternoon. My colleagues and I remain squarely focused on achieving our dual mandate goals of maximum employment and stable prices for the benefit of the American people. Our economy is strong overall and has made significant progress toward our goals over the past two years. The labor market has cooled from its formerly overheated state. Inflation has eased substantially from a peak of 7 percent to an estimated 2.2 percent as of August. We are committed to maintaining our economy’s strength by supporting maximum employment and returning inflation to our 2 percent goal.Today, the Federal Open Market Committee decided to reduce the degree of policy restraint by lowering our policy interest rate by 1/2 percentage point. This decision reflects our growing confidence that, with an appropriate recalibration of our policy stance, strength in the labor market can be maintained in a context of moderate growth and inflation moving sustainably down to 2 percent. We also decided to continue to reduce our securities holdings. I will have more to say about monetary policy after briefly reviewing economic developments.Recent indicators suggest that economic activity has continued to expand at a solid pace. GDP rose at an annual rate of 2.2 percent in the first half of the year, and available data point to a roughly similar pace of growth this quarter. Growth of consumer spending has remained resilient, and investment in equipment and intangibles has picked up from its anemic pace last year. In the housing sector, investment fell back in the second quarter after rising strongly in the first. Improving supply conditions have supported resilient demand and the strong performance of the U.S. economy over the past year. In our Summary of EconomicProjections, Committee participants generally expect GDP growth to remain solid, with a median projection of 2 percent over the next few years.In the labor market, conditions have continued to cool. Payroll job gains averaged 116 thousand per month over the past three months, a notable stepdown from the pace seen earlier in the year. The unemployment rate has moved up but remains low at 4.2 percent. Nominal wage growth has eased over the past year and the jobs-to-workers gap has narrowed. Overall, a broad set of indicators suggests that conditions in the labor market are now less tight than just before the pandemic in 2019. The labor market is not a source of elevated inflationary pressures. The median projection for the unemployment rate in the SEP is 4.4 percent at the end of this year, 4 tenths higher than projected in June.Inflation has eased notably over the past two years but remains above our longer-run goal of 2 percent. Estimates based on the Consumer Price Index and other data indicate that total PCE prices rose 2.2 percent over the 12 months ending in August; and that, excluding the volatile food and energy categories, core PCE prices rose 2.7 percent. Longer-term inflation expectations appear to remain well anchored, as reflected in a broad range of surveys of households, businesses, and forecasters, as well as measures from financial markets. The median projection in the SEP for total PCE inflation is 2.3 percent this year and 2.1 percent next year, somewhat lower than projected in June. Thereafter, the median projection is 2 percent.Our monetary policy actions are guided by our dual mandate to promote maximum employment and stable prices for the American people. For much of the past three years, inflation ran well above our 2 percent goal, and labor market conditions were extremely tight. Our primary focus had been on bringing down inflation, and appropriately so. We are acutely aware that high inflation imposes significant hardship as it erodes purchasing power,especially for those least able to meet the higher costs of essentials like food, housing, and transportation.Our restrictive monetary policy has helped restore the balance between aggregate supply and demand, easing inflationary pressures and ensuring that inflation expectations remain well anchored. Our patient ...
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    9 mins

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