the AffirmX blog

Regulating Your Institution’s Social Media before It Starts Regulating You

Effective Date: December 11, 2013 If there’s one thing financial institutions can’t avoid anymore, it’s social media. Whether you’ve hopped on the bandwagon already or you’re hoping it will pass you by unnoticed, the FFIEC recommends the following guidance for considering the effect social media could have on your institution, for better or worse. Overview [...]

By |2014-01-14T19:18:44-05:00January 14th, 2014|Blog|Comments Off on Regulating Your Institution’s Social Media before It Starts Regulating You

NCUA’s Final CUSO Rule

Effective Date: June 30, 2014 Overview The NCUA has amended—or rather, significantly expanded—the scope of the existing CUSO (Credit Union Service Organization) rule. Although NCUA does not have direct statutory authority to regulate CUSOs, it does have the authority to regulate the investments and loans a credit union makes to a CUSO. NCUA believes the [...]

By |2014-01-06T16:43:01-05:00January 6th, 2014|Blog|Comments Off on NCUA’s Final CUSO Rule

NCUA’s Final Rule on Charitable Donation Accounts

Effective:  December 19, 2013 Federal credit unions have a new world of investment products opening up to them as of December 19, 2013: charitable donation accounts (CDAs). This capacity was granted when the NCUA issued a final rule to amend Part 721, which deals with Incidental Powers, to allow federal credit unions (“FCUs”) the ability to [...]

By |2014-01-06T16:42:17-05:00January 6th, 2014|Blog|Comments Off on NCUA’s Final Rule on Charitable Donation Accounts

Increasing Diversity by Increasing Self-Assessment

Proposed Interagency Policy Statement Establishing Joint Standards for Assessing the Diversity Policies and Practices of Entities Regulated by the Agencies If you are a financial institution regulated by the OCC, the Fed, the FDIC, the SEC, or the NCUA, diversity policies and practices are evolving. Not only is there a greater expectation to use minority-owned [...]

By |2013-12-03T19:39:02-05:00December 3rd, 2013|Blog|Comments Off on Increasing Diversity by Increasing Self-Assessment

New Waves of Proposed Flood Insurance Rules

Proposed Rulemaking Comments Due Dec. 10, 2013  The compliance world has been deluged with 166 new pages of proposed rulemaking to amend flood insurance rules. Issued by the five federal regulators on October 11, the proposal amends regulations varying from escrow of premiums and fees to the seven rules for private flood insurance. In addition, [...]

By |2013-12-03T19:02:00-05:00December 3rd, 2013|Blog|Comments Off on New Waves of Proposed Flood Insurance Rules

New Mortgage Servicing Rules, Part 7: Policy, Procedures and Requirements

The seventh in a series of posts on the new mortgage servicing rules. CFPB has issued the Final Rule for Mortgage Servicing, which takes effect January 10, 2014. Among the numerous changes to mortgage servicing, there are several amendments to Regulation X (RESPA), including a vague-sounding section entitled Policy, Procedures and Requirements. This provision does not [...]

By |2013-11-19T14:54:23-05:00November 19th, 2013|Blog, Compliance Tips|Comments Off on New Mortgage Servicing Rules, Part 7: Policy, Procedures and Requirements

New Mortgage Servicing Rules, Part 6: Loss Mitigation Procedures

The sixth in a series of posts on the new mortgage servicing rules. CFPB has issued the Final Rule for Mortgage Servicing, which takes effect January 10, 2014. Among the numerous changes to mortgage servicing, the Loss Mitigation section contains specific guidelines to occur prior to the foreclosure process. This section follows similar sections dealing [...]

By |2013-11-19T14:51:31-05:00November 19th, 2013|Blog, Compliance Tips|Comments Off on New Mortgage Servicing Rules, Part 6: Loss Mitigation Procedures

New Mortgage Servicing Rules, Part 5: Continuity of Contact with Delinquent Borrowers

The fifth in a series of posts on the new mortgage servicing rules. CFPB has issued the Final Rule for Mortgage Servicing, which takes effect January 10, 2014. Among the numerous changes to mortgage servicing, there are several amendments to Regulation X (RESPA), including three new Rules about dealing with delinquent borrowers. These rules are [...]

By |2013-11-11T16:24:13-05:00November 11th, 2013|Blog, Compliance Tips|Comments Off on New Mortgage Servicing Rules, Part 5: Continuity of Contact with Delinquent Borrowers

What is UDAAP and why are examiners focusing on this issue?

UDAAP stands for Unfair, Deceptive, or Abusive Acts or Practices.  The Dodd-Frank Act added the term “abusive” to the existing Unfair, Deceptive Acts or Practices Act in response to issues arising from the mortgage crisis and from certain credit card practices.  The Dodd-Frank also gave authority to the CFPB to take enforcement actions, in addition [...]

By |2013-11-07T03:52:25-05:00November 7th, 2013|Blog, Compliance Tips|Comments Off on What is UDAAP and why are examiners focusing on this issue?

CFPB Examination Procedures for Remittance Transfers

The CFPB has released the examination procedures for the new Remittance Transfer Rule, which is an amendment of Regulation E or Electronic Funds Transfer Act (EFTA). The final rule went into effect on Monday October 28th. 2013.  The CFPB examination procedures contain a breakdown of audit procedures, a summary of the regulation itself and a [...]

By |2013-11-05T16:56:40-05:00November 5th, 2013|Blog|Comments Off on CFPB Examination Procedures for Remittance Transfers