As noted in part I, compliance requirements will continue to be complex and ever-changing, and will require a comprehensive and collaborative approach from employees across credit union departments.
Here are more top regulatory issues to watch in 2019:
The Consumer Financial Protection Bureau (CFPB) announced amendments to the agency’s 2016 prepaid accounts rule last January. The rule created “comprehensive protections” for prepaid accounts under Regulation E (Electronic Fund Transfer Act) and Regulation Z (Truth in Lending Act).
The most recent changes extended the overall effective date of the rule by one year to April 1, 2019. They also:
CUNA continues to seek clarity on several issues under the Telephone Consumer Protection Act (TCPA) to reduce confusion for credit unions trying to comply with the law.
The Federal Communications Commission (FCC) began re-examining its TCPA interpretation after the D.C. Circuit Court challenged the legality of the 2015 Omnibus TCPA Declaratory Ruling and Order [PDF].
CUNA requested that the FCC consider:
In December, FCC fulfilled the last requested bullet on this list by approving a report and order to create a reassigned numbers database to combat unwanted robocalls.
CUNA has strongly pushed for such a database as part of its ongoing advocacy to resolve issues related to the TCPA.
Stay tuned for further developments on the database and other TCPA issues.
The agency will likely issue advance notices of proposed rulemaking (ANPRs) or notices of proposed rulemaking on these regulations within the first six months of 2019:
Note that these time frames are subject to change.
Contact the CUNA Compliance Team at firstname.lastname@example.org.