February 2011   

in this issue:  FREE Webinars     Small CU Staff Survey     Compliance      Low-income Rule     CUNA Exam Survey
Contact SCUNet

NCUA is offering a FREE training program in the Richmond and Philadelphia areas. The workshop discussion items include:
  • Issues facing credit unions
  • NCUA - Consumer Protection Office - What It Means to YOU
  • Duties of federal credit union board of directors
  • Basic financial literacy requirements
  • Due diligence and evaluating payment system service providers
  • Examination issues

For more information or to register, click here.

FREE Product Showcase Webinars
Appraisal Regulations
Update & Overview

February 10, 2011 
10:00 a.m. EST

MDA Lending Solutions, along with PCUA Compliance staff,
will give an overview of NCUA Letter No. 10-CU-23 regarding
best practices in real estate appraisals. Click here to register.

Delivering Value to Members & Your Balance Sheet through Private Student Lending
February 16, 2011 
2:00 p.m. EST

Credit Union Student Choice will lead a discussion on how this CUSO delivers economic value to your members, and positive returns to your bottom line.
Click here
to register.

TEACUP Group Consumer Education Program
The Erie Area Credit Union Partnership continues its community awareness program with a third consumer education workshop - ID Theft: Who's Got Your Number?  Community awareness is just one way the 11 credit unions in the partnership collaborate to educate consumers of the benefits of credit union membership.  For more information on TEACUP go to www.myeriecu.com

If you'd like to discuss how you can get a collaboration going with your area credit unions, contact Rick Myxter by e-mail or call 800.932.0661, extension 5214.

Small Credit Union Staff Survey
CUNA's Small Credit Union Committee has provided SCUNet with the Executive Summary of the 2010-2011 Small Credit Union Staff Survey. You may find this document helpful as you cope with salary administration issues.

Compliance Q&A:
Risk Based Pricing Notice Requirements

Q: I've heard we need to give members a special notice if they qualify for our preferred loan rates. Is this accurate? And, with so many different forms of this notice, how do I know which one is the right one to use?
This is the final piece of the FACT Act: Section 311(a). As of January 1, 2011, credit unions engaged in risk-based pricing using consumer reports are required to provide a special notice “if a person receives credit on terms materially less favorable than terms offered to most members.”

Risk Based Pricing Notices
There are 5 model forms for risk based pricing notices and alternative credit score disclosures. The forms will vary according to the type of loan, with designations of B-1/H-1 through B-5/H-5 (Federal Reserve uses the "B" designation; the Federal Trade Commission (FTC) uses an "H." Whether you reference Federal Reserve or the FTC, the forms are essentially the same.

B-1/H-1 Risk Based Pricing Notice
B-2/H-2 Account Review Risk Based Pricing Notice
B-3/H-3 Credit Score Disclosure, secured by residential real property
B-4/H-4 Credit Score Disclosure, not secured by residental real property
B-5/H-5 Credit Score Not Available

Detailed information on the FACT Act: Section 311(a) can be found by visiting the Association website, and selecting InfoSight.

Is this Policy Required?
Do you know which policies you are required to have and which ones are optional?
CU PolicyPro can assist you with this task. Choose “CU PolicyPro Tools,” then “Content_Guidelines.” This listing will tell you if a policy is:

  • Mandatory – credit union must have a policy covering the subject matter contained in the CU PolicyPro Policy
  • Mandatory if service/product offered – if the credit union offers the service or product addressed in the policy, it must have a written policy regarding the service/product
  • Compliance Mandatory – the credit union need not have a specific policy but must comply with the subject matter of the policy
  • Compliance Mandatory if offered – the credit union need not have a specific policy but must comply with the subject matter of the policy if service/product is offered
  • Recommended – credit union need not have a policy covering the subject matter and the contents do not reflect compulsory actions but we recommend both the adoption of the policy and compliance with its contents
  • Optional – whether to have the policy or to conform to the policy is entirely up to the business judgment of the credit union

For help in taking full advantage of CU Policy Pro, contact PCUA Compliance & Operations Officer Elaine Royer at 800.932.0661, extension 5341.

NCUA Amends Low-income Rule
Section 701.34 of NCUA regulations has been amended to clarify the definition of “low-income members” in determining a credit union’s low-income designation.  Credit unions of all asset size may qualify for the designation.  If you have not determined eligibility or have been denied eligibility prior to August of 2010, it is recommended that you contact your NCUA Examiner and ask for an analysis of member accounts. Low-income designation qualifies a credit union for financial assistance, grants and loans through the NCUA administered Community Development Revolving Loan Fund. Click here for the revised regulation.

CUNA Web-based Examination Survey
Your credit union now has the capability to critique your most recent examination.  The information you provide will be used by CUNA’s Economic and Research Department to analyze trends and track examination and supervisory related issues on an on-going basis.  This information will be treated as strictly confidential and only reported as summary information without identifying individual credit unions.  More detailed information and the form can be found on CUNA’s website.

Pennsylvania Credit Union Association
4309 N Front Street, Harrisburg, PA 17110    800.932.0661   http://www.pcua.coop

You have an opportunity to opt-out of receiving further e-mail messages by e-mailing the Association at optout@pcua.coop or sending an opt-out notice to the Pennsylvania Credit Union Association.