From Financials to the NCUA, Schumacher Takes What Comes to Him

You would have thought that they were at one of our conferences. I am sure our conference this year will cover many of the topics that they discussed and more. Can't wait!!!!!
What was billed as a presentation on essentials in credit union board financial education essentials evolved into discussion of topics ranging from the NCUA’s director education requirements to peer comparisons. *** Read More; From Financials to the NCUA, Schumacher Takes What Comes to Him: MAUI —

A New Accounting Model For Loan Loss Allowances

What’s going on? Well, the Generally Accepted Accounting Principles (GAAP) in the U.S. is based on the “incurred loss” model. This framework requires that before an allowance for loan loss is established, it must be probable, based on events that have already occurred, that a lender will not be able to collect principal and interest payments that are required under the contractual terms of the loan. If the impairment event has not already occurred, or if it is less than probable that a loss will be incurred, then at least in theory, no allowance is established.

A New Accounting Model For Loan Loss Allowances

Updated Reg B Adverse Action Address

Updated Reg B Adverse Action Address:

Written by Steve Van Beek

As part of their Regulation B adverse action notices, credit unions are required to provide the name and address of the Federal agency which administers compliance with the Equal Credit Opportunity Act (ECOA) for the credit union. Until recently, FCUs needed to include the appropriate NCUA Regional Office. NCUA's creation of its Office of Consumer Protection (OCP) resulted in the OCP taking over the requirements from each Regional Office.

The Problem? While NCUA send out a few generic notices regarding updating the address to the Office of Consumer Protection, the language in Regulation B - specifically Appendix A - was not updated.

Thus, credit unions looking at the language of Regulation B were being provided with different information than the informal notices sent by NCUA.

The Clarification? The CFPB's republishing of Regulation B into 12 CFR 1002 also included an update of Appendix A to reflect the new address for NCUA's OCP that should be used for adverse action notices.

The underlying requirement for including the agency address on adverse action notices comes from 12 CFR 1002.9(a)(2) and (b)(1).

The CFPB's Appendix A now includes this information (for FCUs under $10 billion on assets):

"d. Federal Credit Unions: National Credit Union Administration, Office of Consumer Protection (OCP), Division of Consumer Compliance and Outreach (DCCO), 1775 Duke Street, Alexandria, VA 22314."

Note: Credit unions over $10 billion need to include the CFPB's name and address.

The Timing? The CFPB's republishing indicates that institutions have until January 1, 2013 to make the change. Here is from 12 CFR 1002.9(b)(1) of Regulation B:

"(b) Form of ECOA notice and statement of specific reasons. (1) ECOA notice. To satisfy the disclosure requirements of paragraph (a)(2) of this section regarding section 701(a) of the Act, the creditor shall provide a notice that is substantially similar to the following: The Federal Equal Credit Opportunity Act prohibits creditors from discriminating against credit applicants on the basis of race, color, religion, national origin, sex, marital status, age (provided the applicant has the capacity to enter into a binding contract); because all or part of the applicant's income derives from any public assistance program; or because the applicant has in good faith exercised any right under the Consumer Credit Protection Act. The Federal agency that administers compliance with this law concerning this creditor is [name and address as specified by the appropriate agency or agencies listed in Appendix A of this part]. Until January 1, 2013, a creditor may comply with this paragraph (b)(1) and paragraph (a)(2) of this section by including in the notice the name and address as specified by the appropriate agency in Appendix A to 12 CFR Part 202, as in effect on October 1, 2011."

Appendix A to the Federal Reserve's Regulation B (12 CFR 202) is located here and reflects the Regional Offices.

My understanding is state-chartered credit unions would continue to include the FTC information on their adverse action notices. See Item 9 under Appendix A for "All Other Creditors Not Listed Above."

***

The CFPB discussed the January 1, 2013 timeframe in more detail in the preamble to the republished Regulation B. I know quite a few FCUs have already made the address changes to their adverse action notices, but those who haven't should begin the process now.

A potential benefit of the CFPB's January 1, 2013 timeframe is it clarifies that notices that were not updated previously were still in compliance with Regulation B. If an examiner or auditor indicates your credit union should have updated your notice earlier, I'd show them the language in 12 CFR 1002.9(b)(1) and then work towards getting the notice updated.

Frequently Asked Questions (FAQs) about the January 2010 advisory on Interest Rate Risk

"The Federal Financial Institutions Examination Council today released answers to Frequently Asked Questions (FAQs) about the January 2010 advisory on Interest Rate Risk Management. These FAQs are being adopted by the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, the National Credit Union Administration, and the State Liaison Committee (collectively, the “financial regulators”). "
 Interagency Advisory on Interest Rate Risk Management Frequently Asked Questions. Click here to view the FAQs. ​

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Bucks Blog: Big Banks Struggle to Help Customers on Twitter

Customers like the speed of sending a question to their bank by Twitter, but big banks find this form of customer service to be challenging. Bucks Blog: Big Banks Struggle to Help Customers on Twitter:

Why did you leave your last job?

Why did you leave your last job?” The question can strike fear in even the most confident candidate. Whether your answer is simple or complex, being asked to talk about it puts you on the spot, and it can be tricky to balance the truth while still painting yourself in the best possible light to your hopefully-soon-to-be employer. **** The Secret to Answering "Why Did You Leave Your Last Job?" - Forbes

How to Track Profit and Loss

"Credit cards have long been a high profit product for credit unions, which historically have been able to count on average Return on Assets of 3-6% on their card programs. A recent combination of economic forces and regulatory changes, however, has seriously impaired profitability. With 1-in-8 card portfolios losing money," How to Track Profit and Loss:

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Best Bank Account Interest Rates - Summary for Week Ending January 7, 2012

"The New Year didn't start off good for savers. Several banks and credit unions lowered their savings and checking account rates. The rate cut that we learned about in December took effect at Alliant Credit Union this week. " **** Best Bank Account Interest Rates - Summary for Week Ending January 7, 2012:

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CUs Reminded on Overdraft Consistency

Northwest Credit Union Association bulletin stresses transparency, cites new class action suit against bank. CUs Reminded on Overdraft Consistency:

NCUA Conserves Philadelphia CDCU

NCUA ends first week of 2012 with first conservatorship of year: Philadelphia's People for People CDCU. **** NCUA Conserves Philadelphia CDCU:

Bernanke Claims Fed Has No Intention of Bailing Out Europe But Actions Speak Otherwise

Fed swaps a stunning $100 billion with ECB in three weeks ended December 29. **** Bernanke Claims Fed Has No Intention of Bailing Out Europe But Actions Speak Otherwise:

How To Be More Interesting (In 10 Simple Steps) - Forbes

1.Go exploring.
Explore ideas, places, and opinions. The inside of the echo chamber is where are all the boring people hang out." ****How To Be More Interesting (In 10 Simple Steps) - Forbes: "

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Five Overused Resume Phrases

When it comes to resumes, recruiters have seen it all. Some are clever and creative, and some contain outright blatant untruths. What hiring managers see most, however, is a parade of the same old tired words and phrases that don't tell them anything useful about the candidates. These words have become standard fare and ... Five Overused Resume Phrases: By Angie Mohr

CU-24

"Credit Union 24 is a credit union-owned, full-service EFT network that brings nationwide ATM and point-of-sale (POS) access to credit unions. Founded as a credit union alternative more than 30 years ago, Credit Union 24 offers a flexible, cooperative EFT environment designed to empower credit unions to " *** Firefighter - National Coalition of Firefighter's Credit Unions NCOFCU:

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10 Startup Survival Tips in the Age of the Platform - Forbes

10 Startup Survival Tips in the Age of the Platform - Forbes: "Every startup, as well as mature business, needs to learn as much as possible from Amazon, Apple, Facebook, and Google, who have set the standards for fast growth and success in today’s business world. These companies, designated the “gang of four” by "*** 10 Startup Survival Tips in the Age of the Platform - Forbes: *

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Why Every Entrepreneur Needs a Personal Board of Directors

Our society emphasizes friends, family and co-workers as essential parts of our emotional and professional support system. Friends can offer distraction and encouragement, family members give unconditional love and co-workers may provide a sense of camaraderie and even professional advice. However, there are times when we need a fourth type of support in the form ... Why Every Entrepreneur Needs a Personal Board of Directors:

Four Tips for Conflict-Busting Conversations | 2012-01-01 | Credit Union Magazine

"Disagreements, disputes, and differences are normal in any workplace. The hard part is moving past conflict into honest, open discussion.

These tips from “The Exchange: A Bold and Proven Approach to Resolving Workplace Conflict,” can help managers turn meetings with conflicting employees into productive conversations:" **** Four Tips for Conflict-Busting Conversations | 2012-01-01 | Credit Union Magazine:

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Improve Your Credit Card Program In 3 Key Ways

"Let’s state the obvious. Every credit union would love to find more loans. The U.S. economy is not generating enough loan demand to fill supply. And, therefore, competition for new loans is intense in all ways, including marketing, pricing, and up-front incentives." Improve Your Credit Card Program In 3 Key Ways:

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Readers Choice: Top 10 Most Popular Stories of 2011

The list of low-hanging fruit might read like a list of “duhs,” but many banks and credit unions make excuses and bury their heads in the sand. SEE MORE. What is a brand's personality and why is it important? This how-to article provides seven ... Readers Choice: Top 10 Most Popular Stories of 2011:

The Seven Habits of Spectacularly Unsuccessful Executives

If you exhibit several of these traits, now is the time to stamp them out from your repertoire. If your boss or several senior executives at your company exhibit several of these traits, now is the time to start looking for a new job. *** The Seven Habits of Spectacularly Unsuccessful Executives: