On Friday November 22, 1013, NCUA issued Letter
13-CU-13 to all federally insured credit unions. The letter summarizes the
changes NCUA made to the credit union service organizations regulations. Click here to
view the letter. The letter also contains links to the final
rule and Appendix
A: CUSO Reporting Requirements.
Compliance and Risk Management Department
For comprehensive online resources, visit League InfoSight.
The Compliance and Risk Management Department (CRMD), a partnership between the South Carolina and North Carolina Credit Union Leagues, offers enhanced compliance and risk management assistance to League-member credit unions, addressing these and other topics:
The Bank Secrecy Act (BSA)
NCUA rules and regulations
Deposit account issues
Lending compliance and regulations
Fraud rights and responsibilities
Electronic funds transfers
Board of directors’ rights and responsibilities
For direct consultation, member credit unions can call CRMD at 803-781-5400 or 800-235-4290, then select option 5—or send questions to CRMD staff by e-mail.
While accuracy is top priority, the CRMD does not render legal or tax advice. If your question is of a complex nature or requires a legal opinion, you may be referred to appropriate professional counsel.
For more information on national training for compliance available through CUNA, click here.
Fraud-Net is a dynamic, secured, online database created to help financial institutions and law enforcement in the fight against financial crime.
For more information, please contact Fraud-Net.
Over two years ago the CFPB began the process ofintegrating
the RESPA and TILA mortgage disclosures, as required by the Dodd-Frank Act.
Wednesday, November 20 the CFPB published the final
rule for implementing these new forms, with an effective date of August 1, 2015.
While these new forms may make the mortgage loan process easier for
consumers to understand,compliance with the new forms is going to entail
lots of time and training. Theare now just two forms the Loan
Estimate and the Closing
For more information on how the new forms were finalized
check out the CFPB's "Know
Before You Owe" page. The League will be releasing more
information in the coming weeks on compliance with this new rule.
Changes to the NACHA operating rules
that support healthcare claims payments and payment-related information went
into effect September 20, 2013. This effective date allowed preparation time
for participants in the ACH network to support federal regulations established
by the Patient Protection and Affordable Care Act. An act that requires health
plans to certify with HHS that they are compliant with the healthcare EFT
standard and the healthcare EFT and ERA operating rules no later than January 1, 2014.
The new rule requires originators
to clearly identify CCD entries that are Healthcare EFT transactions using a
specific identifier. The presence of the healthcare-specific indicator offers
RDFIs certainty in distinguishing Healthcare EFTs from non-healthcare CCD entries,
allowing RDFIs to comply with the rules, as well as specific processing
requests from healthcare accountholders.
Specifically, the rules
require originators of Healthcare EFT transactions to populate the company entry
description field with the value "HCCLAIMPMT.”
RDFIs are then required to provide or make available, either automatically or
upon request by a receiver/member that is a healthcare provider (non-consumer
accountholder), all information contained within the payment related information
field (addenda record) transmitted with the Healthcare EFT Transaction.
The RDFI will be required to
provide or make available the payment related information no later than the
opening of business on the second banking day following settlement of the entry.
The RDFI must offer or make available to the healthcare provider an option to
receive or access the payment related information via a secure, electronic
means that provides a level of security that, at a minimum, is equivalent to
128-bit RC4 encryption technology.
To effectively prepare for the implementation of
this rule, RDFIs should:
For more information
regarding complying with Health Care Payments or any ACH compliance issues
contact Sharon Gerald at 336-580-9008 or firstname.lastname@example.org.
- Educate staff to
recognize a request from healthcare providers to deliver the Payment Related
Information field data of the Healthcare EFT, the CORE‐required
Minimum CCD+Data Elements, or the TRN Reassociation Data Elements. The healthcare provider may ask for the
delivery of the remittance data using one of the preceding titles.
- Have a product
or products available to deliver the remittance data to the healthcare
provider, if it is requested. Remember
delivery option must be via a secure electronic delivery.