WASHINGTON—There are several upcoming regulatory changes credit unions should be aware of, noted NAFCU.
The trade association outlined upcoming dates and deadlines for credit union regulatory compliance requirements:
Sept. 1: The NCUA's second field-of-membership rule, finalized in June, goes into effect. Under the rule, credit unions seeking approval to form, expand or convert to a community charter the option to submit a narrative application to document their field of membership. Although the population limit of statistical areas is maintained at 2.5 million, the rule provides that narrative applications subject to a public hearing may exceed the limit. For communities subdivided into metropolitan divisions, community charter applicants are permitted to designate a portion of the area to be served without regard to division boundaries, NAFCU explained.
Dates to Watch
Oct. 1: The NCUA's final voluntary mergers rule becomes effective. The rule increases the minimum required time for notice to members before a merger vote to 45 days; requires the merging credit union to disclose merger-related financial arrangement increases above $10,000 or 15% of compensation, whichever is greater for covered persons; clarifies the contents and format of the members' notice to increase transparency; and establishes a portal for members of the merging credit unions to provide comments about the proposed merger to the NCUA on its website.
Oct. 1: The BCFP's finalized amendments to its Truth in Lending Act (TILA)/Real Estate Settlement Procedures Act (RESPA) integrated disclosure (TRID) rule became effective October 2017, but mandatory compliance is required for applications received on or after Oct. 1. The amendments codify the Bureau's previously issued informal guidance on the rule and provide additional technical clarifications. They also make adjustments to substantive issues related to tolerance provisions, recording fees and transfer taxes, cooperative units, separate disclosure forms, among others, said NAFCU, which has various resources on the rule available here.