Heather Line April 5, 2024 1:43 pm Question: Good Morning, Heather. We are a federal credit union. In the past, whenever a member has caused a loss to the credit union, we have charged off their loans and closed their account no longer allowing them to be a member of the CU unless they pay us back in full. We have never had a policy on this, it has always been a procedure. So my question is…is this ok to continue to do? Do I need a policy in place? Or put something in our membership booklet? Is this technically a expulsion thing that would now need to go to the board?  Answer:&nbs ..read more

Heather Line March 29, 2024 1:52 pm Question:  Hi Heather. Our credit union is going to offer a limited time certificate promotion.  The car wash next door has a reader board that we have used in the past for marketing, but we’ve never advertised rates.  If we are going to offer a 12 month certificate at 5.25% with an APY of 5.27%, what do we need to disclose to make sure that board is compliant?  Answer: It’s going to be tough to get all required disclosures on the reader board and still have a coherent advertisement. The NCUA’s Truth in Savings Act Regulation has ..read more

Heather Line March 14, 2024 3:46 pm Question: Hi Heather, Do you have a trick for remembering how to complete the “Selling Location” or “Paying Location” and the suspects role “Purchaser/Sender” or Payee/Receiver” fields on the FinCEN SAR form? I always trip myself up for cash structuring SARs. Answer: See Q&A #18 on FinCEN’s SAR FAQs: 18. How do we complete Item 56/68 on the new FinCEN SAR which asks for the financial institution or branch’s “role in transaction,” and provides options for “Selling location,” “Paying Location,” or “Both”? Items 56 and 68 are non-critical fields, ho ..read more

Stephen Nelson March 7, 2024 9:35 am When I’m out and about among our most excellent Utah credit unions, I frequently hear from the old-timers that, “We used to get together a lot. It was great. You knew everyone. You knew what was going on.” That’s why, at the Association, we’re going to start up a new series of round tables—to help strengthen the networking and social fabric of our industry in Utah. Somewhere along the line, getting together has diminished. Many factors contributed. Increased competition. More online resources. Fewer credit unions. Smart phones. Social media. The fina ..read more

Heather Line March 5, 2024 6:48 pm Question: Hi Heather. I remember hearing that we could delay sending an outgoing wire for up to 15 days if we notify the beneficiary, but I can’t find where I read that before and want to review the rule again now. Does that sound familiar at all to you? Do you know where I can find more information about this? Answer: You learn something new everyday (at least I did). It’s a Utah law to prevent financial exploitation. Thanks for the heads up on this one.  Compliance, Elder Abuse, Financial Exploitation, Wire Transfers Back to blog home Pre ..read more

Heather Line February 8, 2024 4:14 pm Question: Hi Heather, Quick question…  We helped a member earlier this year with a reduction of his HELOC interest rate.  An application was completed to ensure that he qualified for the reduction, but a new loan was not completed in our host system.  Do we need to submit a HMDA filing for this application?  Answer: No.  A request for a rate reduction on a current HELOC would not meet the definition of “application” in Reg C, which is, “an oral or written request for a covered loan.”   You only report “applic ..read more

Heather Line January 12, 2024 2:05 pm Question: Hi Heather. I would like your opinion on Regulation U. The way I read it Reg U states any loan secured by stocks would have additional reporting requirements. But some others at my credit union think it means that the reporting is only required if stock is purchased and then used as collateral, but does not apply to existing stock. Could you please give me your insights on this?  Answer: Wow! We NEVER talk about Reg U, which is a regulation that requires certain disclosures be given whenever a loan is secured by margin stock.  Cr ..read more

Stephen Nelson December 15, 2023 10:08 am On December 5, Scott Simpson and I joined league professionals from other NCUA Western Region states to meet with the Western Region Director, Cherie Freed, and several of her top staff members. The meeting is an annual tradition, and over the years we’ve developed a cordial rapport with Cherie. She and her team members are personable and diplomatic. The conversation is always friendly. It’s worth relating a few things that were said. I won’t bore you with a minute-by-minute breakdown of all 3 hours. At the very close of the meeting, after we ..read more

Stephen Nelson October 11, 2023 4:18 pm Today President Biden held a press conference in which he vowed that the Federal government would help middle class American’s by outlawing junk fees. He cast a broad net, which encompassed credit unions. From the official press information: The CFPB is taking action to require large banks and credit unions to provide basic information to consumers without charging fees—meaning no more fees for basic services like checking bank account balances, obtaining a payoff amount for a loan, or getting account information needed for applications. Ul ..read more