The compliance burden will only get heavier in the coming year. In fact, 2013 will be busier than 2012, due to the onslaught of Consumer Financial Protection Bureau (CFPB) mortgage rules.
Your credit union should develop a compliance management system to address this overwhelming workload—the “new normal”—in an efficient way. The CFPB offers the most helpful guidance on creating a compliance management system, which consists of:
• Board of directors and management oversight, which will affect strategic planning;
• A compliance program that includes universal staff training and consistent monitoring;
• An overarching framework for responding to all consumer complaints; and
• Audit coverage of all compliance-related issues.
The subject of dividends has come up in a number of questions to CUNA’s compliance staff recently, making this a good time to address questions with the NCUA’s Truth in Savings Regulation (12 CFR 707).
The CFPB is expected to release its proposal on debt collection in conjunction with a July 28 field hearing in Sacramento, Calif. CUNA has met with the bureau a number of times to address the forthcoming rulemaking.