NASCUS Summaries NCUA 2013 Regulatory Alerts

NCUA Regulatory Alerts

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13-RA-08 Appraisals for Higher Priced Mortgage Loans

September 2013

NCUA issued Regulatory Alert 13-RA-08 to remind credit unions of the January 18, 2014 effective date for the new higher-priced mortgage loan (HPML) Appraisal Rule requirements. Under the rule, a mortgage loan is an HPML if it is a closed-end transaction, secured by a consumer’s principal dwelling, and has an interest rate above a certain threshold. Before originating an HPML, a creditor must:

  • Obtain one or more appraisals meeting specified standards;
  • Provide information to applicants regarding the use of the appraisals; and
  • Give applicants a copy of each appraisal used.

 

Creditors must also consider the requirements of the new Equal Credit Opportunity Act Appraisals and Written Valuations Rule (ECOA Valuations Rule). For more information, see NCUA Regulatory Alert 13-RA-07. NCUA's guidance also links to a small entity compliance guide published by the CFPB.

 

Under the rule, a loan is higher priced if:

  • It is a first-lien mortgage (other than a jumbo mortgage) with an APR that exceeds the Average Prime Offer Rate (APOR) published by the CFPB at the time the APR is set by 1.5% points or more
  • It is a first-lien jumbo mortgage with an APR that exceeds the APOR published by the CFPB at the time the APR is set by 2.5% points or more. A jumbo mortgage is when the principal balance exceeds the limit in effect as of the date the transaction’s rate is set for the maximum principal obligation eligible for purchase by Freddie Mac
  • It is a subordinate-lien mortgage with an APR that exceeds the APOR published by the CFPB at the time the APR is set by 3.5% points or more.

 

The HPML Appraisal Rule exempts the following loans from all of its requirements:

  • Qualified Mortgages, as defined in Regulation Z and the CFPB’s Ability-to-Repay/Qualified Mortgage Rule
  • Reverse mortgages
  • Bridge loans for 12 months or less and intended to be used to acquire a new principal dwelling
  • Loans for initial construction of a dwelling (not limited to loans of 12 months or less)
  • Loans secured by new manufactured homes
  • Loans secured by boats, trailers, and mobile homes

 

If a creditor originates a covered HPML, it must:

  • Within 3 business days after receiving the application, disclose the following statement in writing:“We may order an appraisal to determine the property’s value and charge you for this appraisal. We will give you a copy of any appraisal, even if your loan does not close. You can pay for an additional appraisal for your own use at your own cost.”
  • Obtain a written appraisal performed by a certified or licensed appraiser in conformity with the Uniform Standards of Professional Appraisal Practice (USPAP) and Title XI of FIRREA
  • Have the appraiser physically visit the interior of the property
  • At least 3 business days before the transaction closing date, give the applicant a free copy of each written appraisal conducted for the mortgage

 

In addition, there are rules for credit toward the purchase of flipped properties. If the borrower is purchasing the property for more than 10% above the price for which the seller acquired the property in the past 90 days or more than 20% of the seller's purchase price in the past 91-180 days, than the lender must obtain an additional appraisal from a different qualified appraiser. This additional appraisal must meet the requirements of the original appraisals and also must analyze the difference in the original sales price and the subsequent sales price. Several types of transactions are exempted from the additional appraisal requirement. No additional appraisal is needed if the flipped property is being acquired from:

  • A local, state, or federal government agency
  • A person who acquired the title from the holder of a defaulted mortgage on the property via foreclosure, deed-in-lieu of foreclosure, or other similar judicial or nonjudicial procedures
  • A nonprofit entity as part of a local, state, or federal government
  • A person who inherited the property or acquired it through a court-ordered dissolution of a marriage, civil union or domestic partnership, or through the partition of the seller’s joint or marital assets
  • An employer or relocation agency in connection with an employee relocation
  • A service member who received a deployment or permanent change of station order after purchasing the property

 

An additional appraisal for a flipped property HPML is also not required if the property is located in a presidentially-declared disaster area and regulators waive the requirements nor when the property is located in a rural county designated by U.S. Department of Agriculture as Economic Research Service Urban Influence Codes 4, 6, 7, 8, 9, 10, 11, or 12.

 

The HPML Appraisal Rule overlaps with the ECOA Valuations Rule requiring lenders provide consumers with disclosures and free copies of appraisals and other written valuations. First-lien HPMLs covered by the HPML Appraisal Rule are also subject to the ECOA Valuations Rule. Use of the ECOA Valuations Rule disclosure will comply with the notice requirement of the HPML Appraisal Rule. However in order for disclosure to satisfy both rules, the disclosure must meet the earlier of the two rules deadlines. Credit unions should also remember that while a borrower may waiver receipt of the appraisals under the ECOA Valuations Rule, under the HPML Appraisal Rule there is no waiver provision.

 

Additional compliance resources include the CFPB's Appraisals for Higher Priced Mortgages and Disclosure and Delivery Requirements for Copies of Appraisals. The full text of the HPML Appraisal Rule is published in the Federal Register.

13-RA-07 CFPB’s New Rule on Real Estate Appraisals and Other Written Valuations under the Equal Credit Opportunity Act

July 2013

 

NCUA issued Regulatory Alert 13-RA-07 to provide guidance to credit unions regarding new CFPB rules implementing the Dodd-Frank Wall Street Reform and Consumer Protection Act’s (Dodd-Frank) amendment of the Equal Credit Opportunity Act (ECOA)(Regulation B). See Public Law 111-203, 124 Stat. 1376, section 1474 (2010) and 78 FR 7215 (Jan. 31, 2013).

 

Beginning January 18, 2014, a credit union receiving an application for a first-lien loan to be secured by a dwelling must:

  • Notify applicants in writing within 3 days of receiving the application that they have the right to receive copies of all appraisals and written valuations; and
  • Provide a free copy of the appraisals and written valuations developed in connection with the loan application, promptly after they are completed, or three days before the loan closes, (whichever is earlier) regardless of whether the credit is extended, denied, incomplete, or withdrawn.

 

NCUA's Regulatory Alert also links to a Small Entity Compliance Guide for the rule developed by the CFPB.

 

The new CFPB rules cover applications for closed-end or open-end credit secured by a first lien on a dwelling, including:

  • Consumer loans to purchase a home and loans for business purposes, investment, or leisure purposes
  • Loss-mitigation transactions, such as loan modifications, short sales, and deed-in-lieu transactions, if they are credit transactions covered by Regulation B
  • Loans secured by mobile or manufactured homes and reverse mortgages
  • Time-share loans if they are credit transactions covered by Regulation B

 

Even in the applicant waives the right to receive copies of the appraisal or other written valuations in advance of the closing, copies must still be delivered at or prior to consummation or account opening. Even if the account is ultimately not opened, copies of the appraisal and other written valuations must be sent to the applicant within 30 days.

 

The Regulatory Alert reminds credit unions that they may not charge the applicant fees for photocopying or for the cost of postage to mail copies of appraisals or other written valuations provided pursuant to the rule. However, unless otherwise prohibited by state or federal law, lenders may charge a reasonable fee for the cost of developing an appraisal or other written valuation.

 

Lenders must send valuations to applicants promptly upon completion. The rule defines completion as after the lender had received and evaluated the appraisal or valuation.

 

NCUA's Regulatory Alert also notes that all federal financial institution regulators issued Higher-Priced Mortgage Loans (HPMLs) appraisal rules that required lenders provide free copies of the appraisal to the applicant as well as a statement that any appraisals prepared for the mortgage loan are for the sole use of the creditor and that the applicant may have a separate appraisal conducted at his or her own expense. For transactions covered by both the ECOA Valuation and HPML appraisal rules, you may use the ECOA Valuations Rule disclosure to comply with this notice.

 

 

13-RA-06 CFPB’s Amended Remittance Transfer Rule Compliance Deadline: October 28, 2013

July 2013

 

NCUA's LTCU 13-RA-06 discuss issues relevant to credit unions that send money to foreign countries on behalf of members or non-members within their field of membership and alert them to changes to the remittance transfer rule made by the Consumer Financial Protection Bureau (CFPB). The compliance deadline for the new rule is October 28, 2013.

 

The Alert supplements the information provided in NCUA Regulatory Alert 12-RA-04.

 

The new rule applies to a remittance transfer or an electronic transfer of funds using a remittance transfer provider, that is more than $15 and made by someone in the U.S. sending to a person or business in a foreign country. The rule exempts credit unions that do not provide international wire/ACH transfers in the normal course of business: defined as providing more than 100 remittance transfers in the previous calendar year and in the current calendar year. Credit unions seeking the exemption must count their covered foreign remittances annually. If an exempt credit union surpasses the exemption threshold, it will then have 6 months to come into compliance with the new remittance rules.

 

The text of the final rule with official interpretations is available on the CFPB website. On August 8, the CFPB also released a Small Business Compliance Guide available on its website.

 

Highlights of the final rule:

  • Disclosures - consumers must receive 2 types of disclosures: 1) a pre-payment disclosure, and 2) a receipt when payment is made. The 2 disclosures may be combined in a single document before the consumer pays for the transfer, so long as proof of payment is given when payment is made. The disclosures must include the amount being sent to the designated recipient; the transfer fees and taxes (including any up-front fees) being imposed or passed on to the sender; the total transaction amount including all of the above; the exchange rate; any back-end fees charged the recipient; and total to be received by recipient.

 

  • Covered third-party fees - As noted above the sender's institution has disclosure obligations covering some fees on the recipient's end. However, fees for receiving a remittance transfer into an account imposed by a designated recipient’s institution that is not acting as the sending institution's agent “non-covered third-party fees” and as such, are not required to be calculated or disclosed.

 

  • Disclaimer - The sending institution's disclosure must include a disclaimer that non-covered third-party fees or taxes collected on the remittance transfer by a person other than the sending institution may apply to the remittance transfer and result in the designated recipient receiving less than the transfer amount.

 

  • Receipt - A proof of payment receipt must be provided to the sender that repeats the information in the first disclosure. The receipt must also disclose the date when funds will be available to the designated recipient; the recipient’s name and contact information; a statement of the sender’s error resolution and cancellation rights; and the sending institution's name, telephone number and website address. The receipt must also inform the sender that questions and complaints may be directed to the CFPB (with contact information) and for state-chartered credit unions the state regulator's contact information.

 

While the final rule requires that disclosures generally must be accurate at the time the sender pays for a remittance transfer, it creates three exceptions to the accuracy requirement that permit the disclosure of estimates for the applicable exchange rate, back-end fees and taxes and total funds to be received:

1) Until July 21, 2015, if the sending institution cannot determine accurate amounts beyond its control (the example is given of the exchange rate being set by the designated recipient’s institution)

2) The CFPB has published a list of countries where either the laws of the country, or the method by which transactions are made in the recipient country, do not permit a determination of fees. A permanent exemption applies in these cases.

 

3) The third exception allows estimates for transfers scheduled for 5+ business days before the date of transfer.

 

The new final rule also addresses error resolution procedures, requiring the sender be given

30 minutes to cancel a transfer after making payment. Senders must be able to get their money back, at no additional cost, within three business days of the sending institution's receipt of notice of cancellation. Sending institutions are also required to investigate reports of problems with transfers and in certain cases refund or resend (at no additional charge) the transfer. Records of errors must be maintained for 2 years.

 

There is also an exception for the situation where the sending institution transfers funds to the wrong account because the sender provided an incorrect account number or routing number. If the sending institution uses reasonably available means to verify the receiving institution identifier and name information; provided notice to the sender before payment that the sender could lose the transfer amount if the sender provided incorrect information; and tried to recover the funds once the mistake was realized, then liability is limited and the sending institution would not bear the loss of the funds.

Finally, NCUA's Regulatory Alert advices credit unions to become familiar with the new remittance transfer requirements and track the number of international wire transfers and international ACH transfers completed each year. NCUA recommends credit unions modify data processing systems, as necessary, to generate proper terms and content for the disclosures and develop written policies and procedures to ensure compliance. with the error resolution provisions. Your policies and procedures should specifically address:

 

 

13-RA-05 New Escrow Requirements Under Truth in Lending Act

July 2013

 

NCUA Regulatory Alert 13-RA-05 discusses amendments to Regulation Z which lengthen the time a mandatory escrow account must be maintained from 1 year to 5 years for a higher-priced mortgage loan (HPML) secured by a first lien on a principal dwelling. The final TILA Escrow Rule became effective on June 1, 2013.

 

After 5 years, the escrow account may be terminated if the underlying debt obligation is terminated or the borrower requests the escrow account be canceled. However in order to cancel the escrow account after 5 years at borrower request, the following must be met:

  • the unpaid principal balance of the loan must be less than 80% of the original value of the property securing the underlying debt obligation
  • the borrower must not be currently delinquent or in default on the underlying obligation

 

If either of the above requirements is not met, the escrow account must be maintained beyond the 5 years. In addition, the following exceptions do not require an escrow account for an HPML:

  • Transactions to finance the initial construction of a dwelling
  • Transactions secured by shares in a cooperative
  • Temporary or “bridge” loans with terms of 12 months or less
  • Open-end credit (such as a home equity line of credit)
  • Insurance premiums the borrower purchases but you do not require
  • Reverse mortgages and/or subordinate liens

 

Certain financial institutions are exempted from the new rules. Credit unions meeting these 4 conditions are eligible for an exemption from the escrow requirements:

  • Made 500 or fewer first lien mortgages during the preceding calendar year
  • Had less than $2 billion in total assets, as of December 31 of the preceding year
  • Originates more than half of its first lien mortgages in a rural or underserved area
  • Does not escrow for any mortgage obligation currently serviced by the credit union or an affiliate

 

A creditor may rely, as a safe harbor, on the list of counties published by the CFPB to determine whether a county qualifies as rural or underserved for a particular calendar year.

 

However, even if a credit union meets all four conditions, if it plans to sell HPML obligations to another entity that does not meet the exemption requirements, then it will have to establish an escrow account for any HPML covered by the rule.

 

For more information, credit unions may view CFPB's Small Entity Compliance Guide for the TILA Escrow Rule.

 

13-RA-04 Garnishment of Accounts Containing Federal Benefit Payments

July 2013

NCUA Regulatory Alert 13-RA-04 discusses a new final rule regarding garnishment of accounts that may contain protected federal benefits payments. The new rule was published on May 29, 2013 and became effective June 28, 2013.

This Regulatory Alert supersedes and replaces NCUA’s Regulatory Alert 11-RA-04 (July 2011).

 

Certain federal benefit payments are protected under federal law from being accessed or “garnished” by creditors, other than the United States government and certain State agencies, through a garnishment order or similar written instruction issued by a court. Protected benefits include:

  • Social Security and Supplemental Security Income benefits
  • Veterans benefits
  • Federal Railroad retirement, unemployment and sickness benefits
  • Civil Service Retirement System benefits
  • Federal Employee Retirement System benefits

 

Within 2 business days of receiving a garnishment order, a credit union should determine whether the order was obtained by the United States or issued by a State child support enforcement agency. Such garnishments should contain a “Notice of Right to Garnish Federal Benefits." For orders obtained by the United States or issued by a State child support enforcement agency, a credit union should follow its standard procedures for handling a garnishment order.

 

For all other garnishment orders, a credit union must do a 2 month lookback on all accounts owned by the individual subject to the garnishment order to determine if there are protected federal benefits payments. If one or more protected benefit payments were directly deposited into an account during the “lookback period,” the account holder must be given full access to the lesser of (1) all benefit payments posted to the account over the two-month period; or (2) the account balance at the time the account was reviewed. This is the “protected amount” and may not be frozen or garnished.

 

For any funds in excess of the protected amount, standard procedures for handling garnishment orders apply. Credit unions should also note:

  • Garnishment fees may not be collected from the protected amount.
  • Records of account activity and actions taken in handling garnishment orders sufficient to demonstrate compliance with the rule must be maintained for at least two years from the date of receipt of a garnishment order.
  • Account holders must be notified within 3 days of completing the account review if there funds in excess of protected funds that are subject to garnishment.

13-RA-03 Guidance on Biggert-Waters Flood Insurance Reform Act of 2012

April 2013

 

NCUA issued Regulatory Alert 13-RA-03 to notify credit unions of changes to the National Flood Insurance Program (NFIP) and upcoming rulemakings to address statutory amendments. NCUA's Regulatory Alert also links to Interagency Guidance issued by NCUA, the Federal Reserve, the FDIC, the OCC, and the FCA regarding the changes to NFIP.

 

Last year, the Biggert-Waters Flood Insurance Reform Act of 2012 (Biggert-Waters Act) reauthorized and reformed the NFIP through September 30, 2017. NCUA's Alert addresses several changes made by the Biggert-Waters Act including:

  • Changes to premiums and fees - Changes clarified that the premiums and fees that a lender/servicer may charge the borrower include premiums or fees incurred for coverage beginning on the date on which flood insurance coverage lapsed or did not provide sufficient coverage.
  • Refunds - Lenders required to terminate force-placed insurance within 30 days of receiving a confirmation of a borrower’s existing flood insurance coverage and refund all force-placed insurance premiums and any related fees paid for by the borrower during any period of overlap between the borrower’s policy and the force-placed policy.
  • Proof of insurance - Lender or servicer must accept as confirmation of a borrower’s existing flood insurance policy a declarations page including the existing flood insurance policy number and the identity and contact information for the insurance company or agent.
  • Civil money penalties - The maximum civil money penalty for a Flood Act violation was increased to $2,000 per day and the cap on penalties per year was eliminated.
  • Private flood insurance - L enders must accept private flood insurance policies as satisfaction of the mandatory purchase requirement if the coverage provided by the private flood insurance satisfies the standards specified in the Biggert-Waters Act.
  • Escrow of Flood Insurance Payments - Lenders and servicers must establish escrow accounts for flood insurance premiums and fees after July 6, 2014. Generally, credit unions with less than $1 billion in assets and which were not required prior to July 2012 to escrow taxes or insurance by state or federal law, are exempt.

The new law also contains phase ins on rates for premium assessments that vary by personal or business property and by the type of existing premium paid by the property owner at the time of the Act's passage.

13-RA-02 Submission of 2012 Home Mortgage Disclosure Act (HMDA) Data

January 2013

NCUA issued Regulatory Alert 13-RA-02 to inform credit unions subject to HMDA filing requirements of their options for submitting required data as well as NCUA's policy concerning submission of data. Credit unions that were subject to HMDA requirements in calendar year 2012 must submit loan/application register data to the Federal Reserve Board (FRB) by March 1, 2013.

In January, 2012, NCUA issued a Regulatory Alert (12-RA-02) that detailed the thresholds for determining whether a credit union was required to track data in 2012 for filing in March of this year.

NCUA notes that credit unions subject to filing 2012 data on march 1, 2013 have several filing options. Credit unions with 25 or fewer applications data (known as loan/application register data or LAR) may submit data in paper form. However, credit unions with more than 25 LAR data must submit their reports in an automated, machine-readable form under one of the methods discussed at the FFIEC's HMDA web page.

The Regulatory Alert informs credit unions that the FRB prefers receiving the LAR data through the “Submission via Web” option. Another option for credit unions is to submit automated LAR data by e-mail to hmdasub@frb.gov . This option requires proper encryption of the LAR data file using the FFIEC Data Entry Software encryption utility before transmission. In addition to allowing submission by e-mail, the Data Entry Software allows a credit union to export the data onto a diskette/CD-ROM for mailing.

Once the FRB has completed uploading a credit unions data submission it send an "Edit Report" back to the credit union that lists potential data errors. If a credit union does not receive an "Edit Report" within two weeks of submitting data, it should immediately follow up with FRB top ensure its data was received and uploaded.

It is the responsibility of the credit union to ensure its data submission is received and uploaded. Credit unions whose submissions are not successfully uploaded will be reported by the FRB to NCUA as delinquent. Credit unions on the FRB's delinquent report to NCUA could be subject to civil money penalties.

 Several resources are available for credit union subject to the HMDA filing requirements. FFIEC maintains a website with multiple resources for HMDA reporting. Questions concerning HMDA software, data receipt confirmations, data edits, and other issues related to submission of HMDA data can be sent to the FRB by e-mail at hmdahelp@frb.gov. Questions on HMDA filing mayalso be directed to NCUA's Office of Consumer Protection at 703-518-1140 .

13-RA-01 HMDA Data Collection Requirements for 2013

January 2013

NCUA issues a pair of Regulatory Alerts at the start of each year to advice federally insured credit unions of their obligations pursuant to the Home Mortgage Disclosure Act (HMDA). HMDA requirements are codified in the Consumer Financial Protection Bureau's (CFPB) Regulation C. The rule requires any credit union that makes residential mortgage loans and meets all three of the following criteria to collect mortgage loan application data during 2013.

The three criteria are:

1) The credit union’s total assets as of December 31, 2012, exceeded $42 million;

2) The credit union has a home or branch office in a Metropolitan Statistical Area on

December 31, 2012; and

3) During 2012, the credit union originated at least one home purchase loan or refinanced a home purchase loan secured by a first lien on a one-to-four-family dwelling.

 Credit unions meeting all three criteria must collect HMDA data throughout calendar year 2013 and submit the data to the Federal Reserve Board no later than March 1, 2014.

12-RA-03 New Flexibility in Loan Originator Compensation Rules and Pension Plan Payments
April 2012

NCUA issued Regulatory Alert 12-RA-03 to notify credit unions that make closed-end residential mortgage loans about new Truth in Lending rules issued by the Consumer Financial Protection Bureau (CFPB) that provide "new flexibility" in loan originator compensation. Truth in Lending's Regulation Z provides that no loan originator may receive directly or indirectly, compensation that is based on any terms or conditions of a mortgage transaction. Commentary to the rule notes that compensation includes salaries, commissions, and annual or periodic bonuses. "Terms or conditions" of a transaction include the interest rate, loan-to-value ratio, or prepayment penalty. The rules were designed to eliminate incentives for loan originators who might steer borrowers to loan products less favorable to consumers.

The financial services industry has been asking the CFPB about the funding of pensions for mortgage loan originators using earnings derived partly from mortgage lending activities. Prior to the rule's transfer to the CFPB by the Dodd-Frank Act (DFA) the Federal Reserve Board had deemed funding mortgage loan originators' pension plans with earnings derived from closed-end mortgages impermissible under the rule.

On April 2, CFPB released informal guidance softening FRB's interpretation of the rule prohibiting funding qualified pension and profit sharing plans with earnings derived from closed-end mortgages. Per CFPB's guidance, employers would be permitted to contribute to "Qualified Plans" out of a pool of profit derived from loans originated by employees. The new interpretation applies only to "Qualified Plans." CFPB plans to issue guidance with respect to Non-Qualified Plans By January 21, 2013.

12-RA-02 HMDA Data Collection Requirements for Calendar Year 2012
March 2012

NCUA published Regulatory Alert 12-RA-02 to remind credit unions making residential mortgage loans of their obligations pursuant to Regulation C, the Home Mortgage Disclosure Act (HMDA). Regulation C requires credit unions to collect HMDA data associated with mortgage applications processed during 2012, if they meet the following three criteria:

1) The credit union's total assets as of 12/31/2011, exceeded $41 million;
2) The credit union has a home or branch office in a Metropolitan Statistical Area on December 31, 2011; and
3) During 2011, the credit union originated at least one home purchase loan or refinanced a home purchase loan secured by a first lien on a one-to-four-family dwelling.

Credit unions meeting all three criteria must collect HMDA data during calendar year 2012 and submit the data to the Federal Reserve Board by no later than March 1, 2013.

The HMDA is administered by the Consumer Financial Protection Bureau (CFPB), that announced the $41 million threshold on February 15, 2012. The threshold din 2011 was $40 million. NOTE: Although the CFPB will administer the HMDA rule, the Federal Reserve remains the agency that collects the data.

12-RA-01 Submission of 2011 Home Mortgage Disclosure Act (HMDA) Data
February 2012

NCUA issued Regulatory Alert 12-RA-01 to remind credit unions subject to the Home Mortgage Disclosure Act (HMDA) that the deadline for filing HMDA reports is March 1, 2012. The HMDA applies to credit unions located in metropolitan areas that engage in certain types of residential mortgage lending and have assets exceeding $40 million. Specifically, a credit union meeting the following three criteria are subject to filing requirements:

  1. Total assets as of December 31, 2011 exceeded $40 million;
  2. The credit union had a home or branch office in a Metropolitan Statistical Area on December 31, 2011;
  3. During 2011, the credit union originated at least one home purchase loan, or a refinance of a home purchase loan, secured on a one-to-four-family dwelling.

Additional information on filing may be found on the Federal Financial Institutions Examination Council (FFIEC) website http://www.ffiec.gov/hmda/default.htm. Credit unions with 25 or fewer entries on their report may submit the data in paper form. However, credit unions with more than 25 entries must submit their reports in an automated, machine-readable form under one of the methods discussed on the FFIEC website at http://www.ffiec.gov/hmda/contactNCUA.htm.

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