ARTICLE
Compliance Update with Amy K by Amy Kleinschmit, Chief Compliance Officer FedLine – Attestation Due December 31, 2021 In 2020, the Reserve Banks announced the implementation of a new information security program for FedLine Solutions, which provides financial institutions direct electronic access to the Reserve Banks’ payment services. As part of this new program, financial institutions that use FedLine Solutions must conduct an annual assessment of their compliance with the Reserve Banks’ FedLine security requirements and submit an attestation that they have completed the assessment. To the extent any deficiencies or gaps are identified in the self-assessment, institutions must develop a remediation plan to address such deficiencies. As noted above, this Security and Resiliency Assurance Program requires financial institutions that use Fedline Solutions to conduct an assessment of their compliance with the Federal Reserve Banks’ FedLine security requirements and submit an attestation that they have completed the assessment. Additional information, including FAQs, can be found here. CFPB Resources for Preventing Elder Financial Abuse The Consumer Financial Protection Bureau (CFPB) recently issued Guide for family and friends of people living in nursing homes and assisted living communities, which can be found here. The guide discusses steps to protect friends and family from financial abuses, including how to prevent it from happening. This and additional resources can be found here including how to order bulk copies for free. Beware of Data Mining Memes A good reminder from the Oregon FBI’s Tech Tuesday segment was recently posted about building a digital defense against data mining memes and can be found here. Those fun questions on social media are not as innocent as one might think. As explained in the post, “How old would you be if the digits in your age were flipped? What was your first car? What street did you grow up on? Well, the first question obviously gives your age. A quick review of your feed will tell the scammer when your birthday is thanks to those generous friends who wished you well on your special day! Now, he knows your exact DOB… an important piece of personally identifiable info. The other questions can give a scammer the answer to your password reset challenge questions that you set up on your credit cards or bank account or, maybe, even your kids’ school portal.” Some quick tips from the article for protecting yourself online: Use an authenticator app to generate a one-time code that you use to confirm that it’s you logging into a device, website, or service. Make sure you are using the highest security settings possible on your devices and on all your accounts. Use multi-factor authentication whenever possible. That includes something you know (such as a passphrase or PIN), something you have (such as a token or smart card), and something you are (such as a fingerprint). AND - Don’t respond to social media memes asking for info! Reg Z Annual Threshold Updates The Consumer Financial Protection Bureau (CFPB) recently issued its final rule to update various Regulation Z thresholds. The CFPB is required to calculate annually the dollar amounts for several provisions in Regulation Z. This final rule reviews the dollar amounts for provisions implementing TILA and amendments to TILA, including under the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act), the Home Ownership and Equity Protection Act of 1994 (HOEPA), and the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). The final rule can be found here and is effective January 1, 2022. For open-end consumer credit plans under the CARD Act amendments to TILA, the adjusted dollar amount in 2022 for the safe harbor for a first violation penalty fee will increase to $30 and the adjusted dollar amount for the safe harbor for a subsequent violation penalty fee will increase to $41. For HOEPA loans, the adjusted total loan amount threshold for high-cost mortgages in 2022 will be $22,969. The adjusted points-and-fees dollar trigger for high-cost mortgages in 2022 will be $1,148. For qualified mortgages (QMs) under the General QM loan definition in § 1026.43(e)(2), the thresholds for the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) in 2022 will be: 2.25 or more percentage points for a first-lien covered transaction with a loan amount greater than or equal to $114,847; 3.5 or more percentage points for a first-lien covered transaction with a loan amount greater than or equal to $68,908 but less than $114,847; 6.5 or more percentage points for a first-lien covered transaction with a loan amount less than $68,908; 6.5 or more percentage points for a first-lien covered transaction secured by a manufactured home with a loan amount less than $114,847; 3.5 or more percentage points for a subordinate-lien covered transaction with a loan amount greater than or equal to $68,908; or 6.5 or more percentage points for a subordinate-lien covered transaction with a loan amount less than $68,908. For all categories of QMs, the thresholds for total points and fees in 2022 will be 3 percent of the total loan amount for a loan greater than or equal to $114,847; $3,445 for a loan amount greater than or equal to $68,908 but less than $114,847; 5 percent of the total loan amount for a loan greater than or equal to $22,969 but less than $68,908; $1,148 for a loan amount greater than or equal to $14,356 but less than $22,969; and 8 percent of the total loan amount for a loan amount less than $14,356. CU Policy Pro – Start Preparing for 2022! Here are four things from CU Policy Pro that you can do today to ensure you’re ready to hit the ground running in 2022! Log in. Take a few minutes to log in, especially if it’s been a while since you have visited CU PolicyPro. Each credit union has a unique URL to access CU PolicyPro. If you have trouble locating your URL, you can use the client look up utility. If you have any trouble logging in, contact policysupport@cusolutionsgroup.com for assistance. Add Staff. Admin-level users have the ability to set up additional users such as other credit union staff members, members of your board of directors, legal counsel, examiners, etc. You can choose from various levels of access, from Limited-level read-only access to full Admin-level access. If there are other members on your Compliance or Policy team, be sure they have access and know this resource is available. The Managing Users Quick Guide and the Admin Level Training video can help you with creating users and setting appropriate access. Both are found in the Support area of CU PolicyPro. Get Trained. CU PolicyPro is fairly intuitive and easy to use; however, as with any system, simple training can go a long way to help you learn the easiest and most efficient ways to use the system. Log in to CU PolicyPro and visit the Support area for information on getting started, Quick Guides, and in-depth video training for all areas of the system. Ask Questions. Need help getting started? Need more information on user access levels, or how to publish your manual? We have a full suite of Frequently Asked Questions on our support site ranging from Editing and Formatting Policies to Printing, User Management and more! Log in to CU PolicyPro and click on the Support link to view our FAQs! Still not finding the answers you need? Contact our support staff at policysupport@cusolutionsgroup.com. We welcome your questions and are happy to assist! As always, DakCU members may contact Amy Kleinschmit at akleinschmit@dakcu.org with any compliance related questions.
Compliance Update with Amy K
by Amy Kleinschmit, Chief Compliance Officer
FedLine – Attestation Due December 31, 2021
In 2020, the Reserve Banks announced the implementation of a new information security program for FedLine Solutions, which provides financial institutions direct electronic access to the Reserve Banks’ payment services. As part of this new program, financial institutions that use FedLine Solutions must conduct an annual assessment of their compliance with the Reserve Banks’ FedLine security requirements and submit an attestation that they have completed the assessment. To the extent any deficiencies or gaps are identified in the self-assessment, institutions must develop a remediation plan to address such deficiencies.
As noted above, this Security and Resiliency Assurance Program requires financial institutions that use Fedline Solutions to conduct an assessment of their compliance with the Federal Reserve Banks’ FedLine security requirements and submit an attestation that they have completed the assessment. Additional information, including FAQs, can be found here.
CFPB Resources for Preventing Elder Financial Abuse
The Consumer Financial Protection Bureau (CFPB) recently issued Guide for family and friends of people living in nursing homes and assisted living communities, which can be found here. The guide discusses steps to protect friends and family from financial abuses, including how to prevent it from happening. This and additional resources can be found here including how to order bulk copies for free.
Beware of Data Mining Memes
A good reminder from the Oregon FBI’s Tech Tuesday segment was recently posted about building a digital defense against data mining memes and can be found here.
Those fun questions on social media are not as innocent as one might think. As explained in the post, “How old would you be if the digits in your age were flipped? What was your first car? What street did you grow up on? Well, the first question obviously gives your age. A quick review of your feed will tell the scammer when your birthday is thanks to those generous friends who wished you well on your special day! Now, he knows your exact DOB… an important piece of personally identifiable info. The other questions can give a scammer the answer to your password reset challenge questions that you set up on your credit cards or bank account or, maybe, even your kids’ school portal.”
Some quick tips from the article for protecting yourself online:
Use an authenticator app to generate a one-time code that you use to confirm that it’s you logging into a device, website, or service.
Make sure you are using the highest security settings possible on your devices and on all your accounts.
Use multi-factor authentication whenever possible. That includes something you know (such as a passphrase or PIN), something you have (such as a token or smart card), and something you are (such as a fingerprint).
AND - Don’t respond to social media memes asking for info!
Reg Z Annual Threshold Updates
The Consumer Financial Protection Bureau (CFPB) recently issued its final rule to update various Regulation Z thresholds. The CFPB is required to calculate annually the dollar amounts for several provisions in Regulation Z. This final rule reviews the dollar amounts for provisions implementing TILA and amendments to TILA, including under the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act), the Home Ownership and Equity Protection Act of 1994 (HOEPA), and the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).
The final rule can be found here and is effective January 1, 2022.
For open-end consumer credit plans under the CARD Act amendments to TILA, the adjusted dollar amount in 2022 for the safe harbor for a first violation penalty fee will increase to $30 and the adjusted dollar amount for the safe harbor for a subsequent violation penalty fee will increase to $41.
For HOEPA loans, the adjusted total loan amount threshold for high-cost mortgages in 2022 will be $22,969. The adjusted points-and-fees dollar trigger for high-cost mortgages in 2022 will be $1,148.
For qualified mortgages (QMs) under the General QM loan definition in § 1026.43(e)(2), the thresholds for the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) in 2022 will be: 2.25 or more percentage points for a first-lien covered transaction with a loan amount greater than or equal to $114,847; 3.5 or more percentage points for a first-lien covered transaction with a loan amount greater than or equal to $68,908 but less than $114,847; 6.5 or more percentage points for a first-lien covered transaction with a loan amount less than $68,908; 6.5 or more percentage points for a first-lien covered transaction secured by a manufactured home with a loan amount less than $114,847; 3.5 or more percentage points for a subordinate-lien covered transaction with a loan amount greater than or equal to $68,908; or 6.5 or more percentage points for a subordinate-lien covered transaction with a loan amount less than $68,908.
For all categories of QMs, the thresholds for total points and fees in 2022 will be 3 percent of the total loan amount for a loan greater than or equal to $114,847; $3,445 for a loan amount greater than or equal to $68,908 but less than $114,847; 5 percent of the total loan amount for a loan greater than or equal to $22,969 but less than $68,908; $1,148 for a loan amount greater than or equal to $14,356 but less than $22,969; and 8 percent of the total loan amount for a loan amount less than $14,356.
CU Policy Pro – Start Preparing for 2022!
Here are four things from CU Policy Pro that you can do today to ensure you’re ready to hit the ground running in 2022!
Log in. Take a few minutes to log in, especially if it’s been a while since you have visited CU PolicyPro. Each credit union has a unique URL to access CU PolicyPro. If you have trouble locating your URL, you can use the client look up utility. If you have any trouble logging in, contact policysupport@cusolutionsgroup.com for assistance.
Add Staff. Admin-level users have the ability to set up additional users such as other credit union staff members, members of your board of directors, legal counsel, examiners, etc. You can choose from various levels of access, from Limited-level read-only access to full Admin-level access. If there are other members on your Compliance or Policy team, be sure they have access and know this resource is available. The Managing Users Quick Guide and the Admin Level Training video can help you with creating users and setting appropriate access. Both are found in the Support area of CU PolicyPro.
Get Trained. CU PolicyPro is fairly intuitive and easy to use; however, as with any system, simple training can go a long way to help you learn the easiest and most efficient ways to use the system. Log in to CU PolicyPro and visit the Support area for information on getting started, Quick Guides, and in-depth video training for all areas of the system.
Ask Questions. Need help getting started? Need more information on user access levels, or how to publish your manual? We have a full suite of Frequently Asked Questions on our support site ranging from Editing and Formatting Policies to Printing, User Management and more! Log in to CU PolicyPro and click on the Support link to view our FAQs! Still not finding the answers you need? Contact our support staff at policysupport@cusolutionsgroup.com. We welcome your questions and are happy to assist!
As always, DakCU members may contact Amy Kleinschmit at akleinschmit@dakcu.org with any compliance related questions.