National Credit Union Administration

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On October 20, the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, the Consumer Financial Protection Bureau (CFPB), and the National Credit Union Administration (each, a Banking Agency, and collectively, the Banking Agencies) published a proposed rule (the Proposed Rule) that would codify the Interagency Statement Clarifying the Role of Supervisory Guidance issued by the Banking Agencies on September 11, 2018 (the 2018 Statement). The 2018 Statement provided that regulatory guidance did not have the force and effect of law and did not create binding obligations on the public.
Continue Reading Banking Agencies Issue Proposed Rule Addressing Role of Supervisory Guidance

On December 3, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), the Consumer Financial Protection Bureau (CFPB) and the National Credit Union Administration (the Banking Agencies) released interagency guidance related to the use of alternative data for purposes of underwriting credit (the Guidance).
Continue Reading US Banking Agencies Issue Statement on Alternative Date in Credit Underwriting

On October 3, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network, the National Credit Union Administration and the Office of the Comptroller of the Currency released a joint statement related to the permissible sharing of Bank Secrecy Act (BSA) resources.
Continue Reading Federal Banking Agencies Issue Interagency Statement on Sharing Bank Secrecy Act Resources

On April 21, the National Credit Union Administration issued proposed prototype regulations with other financial institution regulatory agencies (Agencies) to likely follow suit. Required under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Act), the rule is intended to (1) prohibit incentive-based payment arrangements that the Agencies determine encourage inappropriate risks by certain financial institutions by providing excessive compensation or that could lead to material financial loss; and (2) require those financial institutions to disclose information concerning incentive-based compensation arrangements to the appropriate federal regulator.
Continue Reading Financial Regulatory Agencies to Issue New Proposed Compensation Rules

On March 21, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the National Credit Union Administration and the Financial Crimes Enforcement Network (collectively, the “regulators”) issued new guidance related to the application of customer identification (CIP) program requirements to prepaid card customers. The regulators issued the guidance in connection with their authority under Section 326 of the US Patriot Act.
Continue Reading Regulators Issue New Guidance Related to Certain Prepaid Cards