Are you ready for the NCUA 2020 Supervisory Priorities?
by Amy Kleinschmit
Chief Compliance Officer
1/23/2020

As discussed in last week’s Memo article, the National Credit Union Administration (NCUA) has issued its 2020 Supervisory Priorities, which can be found here. Among the consumer financial protection topics that will be reviewed by examiners in 2020 for compliance is Electronic Fund Transfer Act (Regulation E).

You can expect examiner’s review of Reg E policies and procedures, and review initial account disclosures. Examiners will also review compliance with Regulation E’s error resolution procedures for when consumers assert an error.

Compliance Resources. To assist credit unions with compliance and other regulatory requirements, be sure to check out CU PolicyPro and our new and improved InfoSight. Both resources are dues-supported – which means they are FREE for affiliated credit unions.

In your CU PolicyPro manual, depending on the scope of your operations, the following Model Policies may be useful:

  • Model Policy 2600: Electronic Fund Transfers
  • Model Policy 2605: International Remittance Transfers
  • Model Policy 2615: ATM/Debit Cards
  • Model Policy 2616: Prepaid Accounts
  • Model Policy 7215: Overdraft Protection (Courtesy Pay)

Be sure to check out your InfoSight resources, which includes a Regulation E checklist that can be found here. Summaries, FAQs, and additional resources can be found here.

Also, in case you missed it at the end of 2019 – The Federal Reserve Outlook Live hosted a free webinar on “Regulation E – Error Resolution Examiner Insights.” This webinar included a discussion of the regulatory requirements for resolving errors for accounts subject to Regulation E. Scott Sonbuchner from the Federal Reserve Bank of Minneapolis, and Yvonne Lunde from the Federal Reserve Bank of New York, provide an overview of the regulatory requirements, discuss the effect of a regulatory amendment to apply the error resolution requirements to prepaid accounts effective April 2019, and review recent error resolution issues raised during examinations and through consumer complaints.

Find this and all archived webinars here.

As always, CUAD members may contact Amy Kleinschmit with any compliance related questions. Be sure to contact her if you need assistance using CU PolicyPro or InfoSight! 

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