CompBlog Wrap-Up features supervisory highlights, mortgage servicing guidance

November 12, 2014

WASHINGTON (11/13/14)--October saw the Credit Union National Association's CompBlog cover topics from mortgage servicing guidance to fair lending. The monthly CompBlog Wrap-Up highlights some of the most important topics from CUNA's compliance staff.

CUNA's compliance experts last month studied the Consumer Financial Protection Bureau's (CFPB) fifth edition of its supervisory highlights report, which discusses major findings from the bureau's supervision of large financial institutions. This CFPB release included the discovery of "unfair or deceptive practices" in student loan servicing, as well as observations that some mortgage servicers lacked any policies and procedures relating to oversight of their service providers.

Other CFPB's supervisory highlights included:

  • Inadequate Home Mortgage Disclosure Act compliance management systems resulting in "severely compromised" data;

  • Unfair, deceptive or abusive marketing of credit card add-on products, resulting in an enforcement action; and

  • Regulation E violations, where institutions would not initiate error investigations until consumers returned dispute confirmation forms.

CompBlog Wrap-Up also reviews a CFPB compliance bulletin to address high-volume mortgage servicing transfers, which provides examples of general transfer-related policies and procedures that examiners may consider when evaluating a credit policies are compliant.

The report also provided a link to CUNA's own examinations survey and encouraged credit unions to describe their most recent examination experiences. 

Other items covered include:

  • An update on fair lending, including highlights of a discussion hosted by several federal regulators, including the National Credit Union Administration;

  • The IRS issued a proposed regulation to remove the 36-month non-payment testing period from the identifiable events that trigger the 1099-C Cancellation of Debt form;

  • Recent cybersecurity assessment observations from the Federal Financial Institutions Examination Council; and

  • The CFPB's final rule amending privacy notice requirements.