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Compliance Update
August 2010

FRB Issues SR Letter on Federal Mortgage Loan Originators

The Federal Reserve Board has issued Supervision and Regulation Letter 10-14 for Federal Mortgage Loan Originators under the S.A.F.E. Act.  The Letter provides information and guidance on the registration expectations under the Act.  The full text of the letter may be found at:  http://www.federalreserve.gov/boarddocs/srletters/2010/sr1014.htm

 


Gift Card Rules Take Effect (in part)

While Congress delayed the effective date of certain portions of the gift card rules issued under the FRB Regulation E, some portions did take effect on August 22nd.  These effective provisions included ones relating to notices, fees and expiration dates.  For more information you can review a summary of the rule at: http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20100323a2.pdf or check out the Regulation E Recent changes site:   http://www.federalreserve.gov/newsevents/press/bcreg/20100811a.htm

 


NCUA Releases Regulation E Opt In Information

On August 3rd, the NCUA released information on the Opt In Requirements for overdraft services as well as a sample opt in notice.  The sample notice may be
found at: 
http://www.ncua.gov/news/press_releases/2010/FedReserveBdRegESampleOptinNotice.pdf 

 


FRB Announces Check 21 Availability Changes

The credit availability schedule on substitute check endpoints contained in FedForward® and FedReturn® deposits will change as a result of changes in presentment transportation servicing at Boston, Windsor Locks, and Baltimore. The changes became effective August 23, 2010.  Follow this link to see the changes:  http://www.frbservices.org/files/communications/pdf/check/080910_availability_changes.pdf

 


FRB Announces Check 21 Availability Changes

The Federal Reserve Banks will modify the credit availability schedule on substitute check endpoints contained in FedForward® and FedReturn® deposits as a result of the closing of the Philadelphia print site. The changes will be effective September 20, 2010.  Follow this link to see the changes:

http://www.frbservices.org/files/communications/pdf/check/
082710_check_21_availability_changes.pdf
  
 

 


FDIC Issues FIL on Overdraft Services

On August 11th the FDIC issued a Financial Institution Letter inviting comments on its Overdraft Payment Supervisory Guidance.  In the Letter the FDIC reminded institutions of its concern and expectations regarding overdraft services systems, including proper monitoring of third parties.  The full text of the letter may be found at:  http://www.fdic.gov/news/news/financial/2010/fil10047.html

 


FDIC Rule Makes Insurance Coverage of $250,000 Permanent

The FDIC amended its insurance regulations and advertising regulations to conform with provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which permanently increased the standard maximum deposit insurance amount (SMDIA) from $100,000 to $250,000. The amendment was effective July 22, 2010.  The final rule is located at:  http://www.fdic.gov/news/board/10AugFRLogo.pdf 

 


OFAC Assesses $607,500 Civil Money Penalty

Compass Bank, Birmingham, AL, has remitted $607,500 to settle allegations of violations of the Sudanese Sanctions Regulations, 31 C.F.R. Part 538 occurring during September 2006. OFAC alleged that Compass Bank acted without an OFAC license or outside the scope of its license by initiating three funds transfers on behalf of one of its clients related to the petroleum or petrochemical industries in Sudan.  The full text of the action may be read at: http://www.ustreas.gov/offices/enforcement/ofac/civpen/penalties/08132010.pdf

 


Financial Regulators Adopt Guidance on Reverse Mortgage Products

On August 16th, the FFIEC released a guidance on reverse mortgages.  The guidance emphasizes the following:

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consumer protection concerns raised by reverse mortgages 

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the importance of financial institutions mitigating the compliance and reputation risks associated with these products 

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the general features of reverse mortgage products 

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the relevant legal requirements and consumer protection concerns raised by reverse mortgages. 

The full text of the guidance may be found at:  http://www.ffiec.gov/pdf/FFIEC_Reverse_Mortgages_FR_notice_081610.pdf

 


FRB Revises Regulation Z for  Loan Originator Compensation Practices

The purpose of the final rule is to protect consumers in the mortgage market from unfair or abusive lending practices that can arise from certain loan originator compensation practices, while preserving responsible lending and sustainable homeownership. The final rule prohibits, among other things, payments to loan originators, which includes mortgage brokers and loan officers, based on the terms or conditions of the transaction other than the amount of credit extended.  The rule takes effect on April 1, 2011 and may be read in its entirety at:  http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20100816d1.pdf  

 


FRB Revises Regulation Z for notice of Sale or Transfer of Mortgage

This rule became effective in May 2009 with interim regulations issued in November 2009 (this is not a typo).  The new regulations are effective January 1, 2011 and may be read at:  http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20100816c1.pdf

 


FRB Issues CA on Revised Interagency Examination Procedures for
Regulation Z

The Federal Reserve Board has issued Consumer Affairs Letter 10-10 regarding examination procedures for Regulation Z.  This CA replaces CA 10-6.  The revisions were issued primarily in response to the Credit Card Accountability Responsibility and Disclosure Act of 2009.  The full text of the letter may be read at: http://www.federalreserve.gov/boarddocs/caletters/2010/1010/caltr1010.htm. 
The examination procedures may be accessed from this letter.

 


NCUA Issues Letter on S.A.F.E. Act

The NCUA has issued Letter to Credit Unions 10-CU-13 regarding the adoption of Part 761 and compliance with the S.A.F.E. Act.  Along with the letter, the NCUA released the regulation and a frequently asked questions document.  They may be accessed at:  http://ncua.gov/Resources/SAFEAct.aspx