Required Reading for the Compliance Geek

May 3, 2022 at 9:02 am Leave a comment

Yours truly is always a little ambivalent when someone gives me a reading suggestion; on the one hand, I love a good recommendation, on the other, there’s an implicit pressure that comes with the suggestion lest you have to sheepishly explain why you haven’t gotten to the book the next time you run into the recommender.  
So, with apologies to those of you who already have a list of compliance material piling up in your virtual in-box, there are two recent publications that all good compliance people should take the time to peruse. 

Most importantly, the CFPB released its Quarterly Compendium Of Supervisory Highlights which it uses to put financial institutions on notice as to its areas of regulatory emphasis in the coming months.  The Spring issue includes many topics with which I have seen credit unions grapple in the past, including mandatory re-evaluation of increased credit card interest rates under the Credit Card Accountability Responsibility and Disclosure Act of 2009 (Credit CARD Act) and continued concerns about the reporting practices of financial institutions under the Fair Credit Reporting Act.  But the issue that the CFPB decided to highlight that I think credit unions would be well advised to look at most closely has to do with GAP car insurance and the refund of excess payments.  This has already been the subject of lawsuits and if the issue is highlighted by the CFPB you can bet it’s one that class action lawyers will continue to scrutinize.   

A second document you should review is one of my personal favorites.  A new Consumer Compliance Outlook report has been issued by the Philadelphia Federal Reserve.  This issue provides you with a comprehensive overview of CDFIs and how to become one.  I know this is an area that many a credit union has been examining and, as usual, the report is concise and useful. 

On that surprisingly upbeat note, enjoy your day.  For the five of you who care about hockey out there in the blogosphere, I am predicting a Tampa Bay-Calgary Stanley Cup but was unfortunately not able to get this certified as acceptable collateral, as my hockey predictions are even worse than those for other sports. 

Entry filed under: Compliance, Regulatory. Tags: , , .

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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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