Visit CUNA’s CompBlog
CUNA’s new compliance blog—“CompBlog”—takes information credit unions have found for years in CUNA’s “Compliance Challenge” and delivers it in a more timely format.
Credit unions have access to new regulatory and compliance developments, Q&As, and musings from CUNA’s compliance team.
E-mail firstname.lastname@example.org with questions or ideas for blog posts. And keep the conversation going with your peers on COBWEB, CUNA’s compliance listserv.
2011 Training Calendar
Visit cuna.org/training-education for program and registration details.
Q Does the credit union have to use the risk-based pricing/credit score notice if it doesn’t use a credit score to set the material terms of credit?
A The credit union is required to provide the risk-based pricing notice with credit score information if it engages in risk-based pricing and uses a credit score to set the material terms of credit. If the credit union doesn’t pull a score, then there’s no question the score wasn’t used to set the credit terms. But if the credit union does pull a credit score, you’ll have to demonstrate the score played no role in setting the material terms of credit. If the credit union can do that, then it wouldn’t have to provide the additional disclosure of credit score information. But, proceed with caution since this may be hard to prove.
Q Our credit union received a follow-up request from a state agency regarding a suspicious activity report (SAR) we previously filed on a member. Can we share the SAR information with the state agency?
A It depends. The Financial Crime Enforcement Network’s (FinCEN) SAR Confidentiality Rule allows the credit union to provide SARs or SAR information to authorized parties only. With state agencies, credit unions must provide this information to:
If the agency doesn’t fall under either of these two categories, it must contact FinCEN directly for access to the requested information.
Visit CUNA’s e-Guide to Federal Laws and Regulations at cuna.org.