Compliance Watch

The Financial Stability Board recently announced its publication of an interim report, “Supervisory and Regulatory Approaches to Climate-related Risks,” that aims to assist supervisory and regulatory authorities in developing their approaches to monitor, manage, and mitigate cross-sectoral and systemwide risks arising from climate change and to promote consistent approaches across sectors and jurisdictions.

The Federal Housing Finance Agency has announced that Fannie Mae and Freddie Mac (the Enterprises) will require lenders to use the Supplemental Consumer Information Form (SCIF) as part of the application process for loans that will be sold to the Enterprises.

Question: We are looking to open accounts online and wonder if we are required to provide account opening disclosures immediately or if we can send them after the account opens for review later. What is the correct timing? Answer: To cite 12 CFR 707.4:

Your members look to you to protect their assets in case an unforeseen disaster occurs, so it’s critical for credit unions to have a blueprint for emergency preparedness.

The CFPB recently issued a report that examines the financial consequences of medical billing and collections endured by individuals and families across the country.

The Department of Treasury announced that OFAC has designated entities and individuals involved in attempts to evade sanctions imposed by the United States and its international partners on Russia.

The Department of Housing and Urban Development released new guidance to reinforce requirements that HUD-subsidized multifamily housing’s marketing and application processes be designed to be inclusive of persons of all races and national origins.

Comments on several items of relevance to credit unions are due in the next several weeks.

The CFPB announced it is invoking a largely unused legal provision to examine nonbank financial companies that pose risks to consumers.

Question: Our credit union operations are only in Oklahoma, but we have members in many other states. Is it appropriate to escheat all dormant funds to the state of Oklahoma? Answer: No. Funds should be escheated to the state in which the member resides.