third quarter 2013 ftc – coppa nacha - operating rules change ncua – loan participations

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Compliance Outlook 2013 Second Quarter - Third Quarter

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Page 1: Third Quarter 2013 FTC – COPPA NACHA - Operating Rules Change NCUA – Loan Participations

Compliance Outlook

2013 Second Quarter -

Third Quarter

Page 2: Third Quarter 2013 FTC – COPPA NACHA - Operating Rules Change NCUA – Loan Participations

Program Overview

Third Quarter 2013

• FTC – COPPA

• NACHA - Operating Rules Change

• NCUA – Loan Participations

Page 3: Third Quarter 2013 FTC – COPPA NACHA - Operating Rules Change NCUA – Loan Participations

Program Overview

Forth Quarter 2013

• CFPB – International Remittance Transfers

• CFPB – Credit Access Rule

Page 4: Third Quarter 2013 FTC – COPPA NACHA - Operating Rules Change NCUA – Loan Participations

FTC - COPPA 7/1/2013COPPA Requires:• Online privacy policy;• Notice to parents;• Parental consenting to information collection and

use;• Parental access to their child’s personal

information;• Parents can prevent further use or collection of

information;• Maintain the confidentiality, security, and integrity

of information; and• Retain personal information collected online from

a child for only as long as is needed for the purpose it was collected.

Page 5: Third Quarter 2013 FTC – COPPA NACHA - Operating Rules Change NCUA – Loan Participations

NACHA - Rules 9/20/2013Operating Rules Change:

• Health Care Payments

• ACH Security Framework

• Notifications of Change for Single Entries

• Stop Payments

Page 6: Third Quarter 2013 FTC – COPPA NACHA - Operating Rules Change NCUA – Loan Participations

NCUA – Loan Participations

7/25/2013

Loan Participation Requirements Amended:

• Purchasing credit unions subject to a concentration limit of $5 million or 100% of net worth, whichever is greater;

• Originating federal credit union risk retention requirement is 10%; risk retention requirement for other originating organizations is 5%, consistent with the requirements under the Dodd-Frank;

• Federally insured credit unions may establish different underwriting standards for loan participations.

Page 7: Third Quarter 2013 FTC – COPPA NACHA - Operating Rules Change NCUA – Loan Participations

CFPB – International Remittance Transfers

• 100 IRT Exemption

• Disclosures

• Temporary Exceptions

Page 8: Third Quarter 2013 FTC – COPPA NACHA - Operating Rules Change NCUA – Loan Participations

International Remittance TransferDisclosures:

Page 9: Third Quarter 2013 FTC – COPPA NACHA - Operating Rules Change NCUA – Loan Participations

International Remittance TransferTemporary Exceptions:

• Applies to credit unions; • Credit Union may estimate the

applicable exchange rate, back-end fees and taxes, and total funds to be received.

• Exceptions are limited and temporary and will only be available for qualified transfers through July 21, 2015.

Page 10: Third Quarter 2013 FTC – COPPA NACHA - Operating Rules Change NCUA – Loan Participations

CFPB – Credit Access Rule

The credit access rule allows:

• Joint-account income as an asset on credit applications.

11/4/2013

Page 11: Third Quarter 2013 FTC – COPPA NACHA - Operating Rules Change NCUA – Loan Participations

Thank you for joining us for this overview of the Credit Union Compliance Connection. Stay

Tuned……..