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Compliance Update with Amy K by Amy Kleinschmit, Chief Compliance Officer All New CU Policy Pro! CU PolicyPro is the perfect complement to InfoSight, providing model policy content for over 230 credit union-specific operational policies. We are pleased to announce the completion of a complete rebuild of CU PolicyPro! The new system includes a beautiful, modern, and easy-to-navigate design to help all users easily find, view and print both model policies and the credit union’s own customized policies. System admins and policy editors now have a whole new toolbox to create, maintain and distribute policies, assign and track policy updates and reviews, upload and share additional documents, view and confirm relevant model policy updates, and manage user access to the policy level. Welcome emails have been emailed to all users and we have already received some great feedback on the new site! Current clients can get more information on the League InfoSight website CFPB – QM Rule Extension The Consumer Financial Protection Bureau (CFPB) issued a final rule to delay the mandatory compliance date for the December 10, 2020 QM final rule. The General QM Final Rule amended Regulation Z to remove the General QM loan definition’s DTI limit (and appendix Q) and replace it with limits based on the loan’s pricing. The General QM Final Rule had an effective date of March 1, 2021, and a mandatory compliance date of July 1, 2021. However, with this recent final rule the mandatory compliance date is delayed until October 1, 2022. This April 2021 Final Rule also affects the expiration of the Temporary GSE QM loan definition or “Patch.” Under the April 2021 Final Rule, the Temporary GSE QM loan definition will expire on October 1, 2022 or the date the applicable GSE exits conservatorship, whichever comes first. HOWEVER, as was discussed in the April 16 Memo article – Fannie Mae recently issued Lender Letter (LL-2021-09) which can be found here and Freddie Mac issued a similar letter (Bulletin 2021-13) found here, which requires that acquired loans meet the revised General Qualified Mortgage (QM) loan definition in the CFPB’s rule that became effective March 1, 2021 (Revised QM Rule). The letter notes that they will no longer acquire loans that are GSE Patch loans that do not meet the Revised QM Rule unless they fall include specific dates detailed in the letters. Exam Prep Earlier in the Memo (April 19) you read about ways to prepare for your next exam, which provided helpful tips like designating a point-person, reviewing past exams and member complaints, and performing internal control audits – for example. As follow-up to those useful tidbits, here are some additional tips to follow as you head into your next exam (to make sure the process goes better than passing a kidney stone): If you prepare everything requested, the exam will be much smoother. Expect examiners to ask for other things after the exam starts. Questions will arise. If you have trouble preparing or have questions, then ask the Examiner-in-Charge. If you don’t prepare, the exam will likely be much more intrusive as they will be asking for things often, and they might need to extend the examination. If you have concerns with how the exam progresses, then talk to the Examiner-in-Charge about it. If you still have concerns, then contact the Supervisory Examiner. To ensure you receive the most effective exam communicate often with the Examiner-in-Charge. Daily meetings are a good idea. This is even more important for remote exams since communication is more difficult. Finally, think of the exam as a collaborative effort. Examiners want the credit union to be successful! 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
All New CU Policy Pro!
CU PolicyPro is the perfect complement to InfoSight, providing model policy content for over 230 credit union-specific operational policies. We are pleased to announce the completion of a complete rebuild of CU PolicyPro! The new system includes a beautiful, modern, and easy-to-navigate design to help all users easily find, view and print both model policies and the credit union’s own customized policies. System admins and policy editors now have a whole new toolbox to create, maintain and distribute policies, assign and track policy updates and reviews, upload and share additional documents, view and confirm relevant model policy updates, and manage user access to the policy level. Welcome emails have been emailed to all users and we have already received some great feedback on the new site!
Current clients can get more information on the League InfoSight website
CFPB – QM Rule Extension
The Consumer Financial Protection Bureau (CFPB) issued a final rule to delay the mandatory compliance date for the December 10, 2020 QM final rule. The General QM Final Rule amended Regulation Z to remove the General QM loan definition’s DTI limit (and appendix Q) and replace it with limits based on the loan’s pricing. The General QM Final Rule had an effective date of March 1, 2021, and a mandatory compliance date of July 1, 2021. However, with this recent final rule the mandatory compliance date is delayed until October 1, 2022.
This April 2021 Final Rule also affects the expiration of the Temporary GSE QM loan definition or “Patch.” Under the April 2021 Final Rule, the Temporary GSE QM loan definition will expire on October 1, 2022 or the date the applicable GSE exits conservatorship, whichever comes first.
HOWEVER, as was discussed in the April 16 Memo article – Fannie Mae recently issued Lender Letter (LL-2021-09) which can be found here and Freddie Mac issued a similar letter (Bulletin 2021-13) found here, which requires that acquired loans meet the revised General Qualified Mortgage (QM) loan definition in the CFPB’s rule that became effective March 1, 2021 (Revised QM Rule). The letter notes that they will no longer acquire loans that are GSE Patch loans that do not meet the Revised QM Rule unless they fall include specific dates detailed in the letters.
Exam Prep
Earlier in the Memo (April 19) you read about ways to prepare for your next exam, which provided helpful tips like designating a point-person, reviewing past exams and member complaints, and performing internal control audits – for example.
As follow-up to those useful tidbits, here are some additional tips to follow as you head into your next exam (to make sure the process goes better than passing a kidney stone):
If you prepare everything requested, the exam will be much smoother.
Expect examiners to ask for other things after the exam starts. Questions will arise.
If you have trouble preparing or have questions, then ask the Examiner-in-Charge. If you don’t prepare, the exam will likely be much more intrusive as they will be asking for things often, and they might need to extend the examination.
If you have concerns with how the exam progresses, then talk to the Examiner-in-Charge about it. If you still have concerns, then contact the Supervisory Examiner.
To ensure you receive the most effective exam communicate often with the Examiner-in-Charge. Daily meetings are a good idea. This is even more important for remote exams since communication is more difficult.
Finally, think of the exam as a collaborative effort. Examiners want the credit union to be successful!
As always, DakCU Members may contact Amy Kleinschmit at akleinschmit@dakcu.org with any compliance related questions.