Regulators Release a “Must Read” Guidance for CUs

June 24, 2020 at 8:41 am Leave a comment

Agencies Issue Joint Examination Guidance

The NCUA yesterday joined with its state and federal counterparts to issue guidance describing examiner expectations during the pandemic.  Needless to say, this is required reading for someone at your credit union today.

What caught my attention most about the wide-ranging explanation of supervisory expectations was the emphasis it placed on institutions engaging in ongoing risk assessments related to the pandemic. For example, the examiners explain that they:

… will review the steps management has taken to assess and implement effective controls for new and modified operational processes. Examiners will assess actions management has taken to adapt fraud and cyber-security controls to manage heightened risks related to the adjusted operating environment. Examiners will also review how management has assessed institutions’ third parties’ controls and service delivery performance capabilities post crisis.”

I know how difficult it is for many of you scrambling around to meet the credit union’s needs on a day-to-day basis to find the time to look at the big picture, but at its most basic level this requirement demonstrates why it’s so important to take a deep breath, sit the team down and memorialize those new policies and procedures you have put in place so that examiners can see how your credit union responded to the pandemic.

AG Reaches $17M Settlement With Mortgage Servicers

New York’s AG announced that she has reached a $17 million settlement with Texas based mortgage loan servicer Caliber which she alleged had engaged in unfair and deceptive practices and violated New York Servicing Regulation Part 419 by, among other things, inadequately explaining to delinquent homeowners the consequences of interest only loan modifications and providing inadequate contact information.  The interesting thing about the settlement findings is that it was based entirely on violations of New York law.

New York Primary Results

Some much anticipated New York State Congressional primaries are too close to call, but it does look like we are on the verge of once again seeing some longtime incumbents losing out to a younger, more liberal, candidate.


Entry filed under: Compliance, COVID-19, Mortgage Lending, New York State, Political, Regulatory. Tags: , , , , .

CFPB Proposes Alternative to the GSE Patch Travel Quarantine Presents New Challenges for Your CU

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Authored By:

Henry Meier, Esq., Senior Vice President, General Counsel, New York Credit Union Association.

The views Henry expresses are Henry’s alone and do not necessarily reflect the views of the Association. In addition, although Henry strives to give his readers useful and accurate information on a broad range of subjects, many of which involve legal disputes, his views are not a substitute for legal advise from retained counsel.

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