3. Lender liability losses
These have increased significantly among credit unions over the last two years. The rise in delinquency, repossession, and foreclosure calls attention to the need to ensure compliance with applicable laws and regulations that govern these procedures.
Be particularly mindful of U.S. Bankruptcy code, Fair Credit Reporting Act, Unfair and Deceptive Trade Practices Act, and Fair Debt Collection Practices Act requirements in your collection and reporting procedures.
Consult with an attorney to ensure processes, procedures, and other member-facing documents (such as “notice of intent to sell”) are in compliance with these acts as well as other applicable statutory laws that may apply to your credit union.
Damages resulting from violations of these laws can be significant.
Take these steps to guard against fraud and other risks: