Regulatory Compliance in Uncharted Territory
Enough already! Never have truer words been spoken in relation to regulatory compliance. Credit unions are at the breaking point, with some already broken. The number of changes to consumer protection laws and regulations is unprecedented.
For the past year. credit unions faced short implementation periods to comply with the CARD Act, MDIA and comprehensive amendments to Regulation Z and RESPA. On a single day in August, the Federal Reserve issued more than 1,000 pages of proposed and interim rules on Regulation Z alone. And credit unions must tackle new privacy and risk-based pricing notices. Early in 2011, credit unions will begin making new Regulation Z disclosures regarding mortgage payment changes and the sale or transfer of mortgages. Credit unions will also need to comply with registration requirements for mortgage originators and ensure mortgage loan origination practices comply with Regulation Z changes. The most sobering news of all is that the biggest compliance challenges could still be a year or two away courtesy of the Dodd-Frank Act.