New NASCUS Summaries Posted
NCUA has issued Regulatory Alert 22-RA-01 to remind credit unions of data collection requirements in 2022 for 2023 filing pursuant to Regulation C.HMDA requires credit unions to collect HMDA data associated with mortgage loan applications processed during 2022, if:
- The credit union’s total assets as of December 31, 2021, exceeded $50 million;
- The credit union had a home or branch office in a Metropolitan Statistical Area on December 31, 2021;
- The credit union originated at least one home purchase loan (other than temporary financing such as a construction loan) or refinanced a home purchase loan, secured by a first lien on a one-to-four unit dwelling during 2021; and
- The credit union originated at least 100 covered closed-end mortgage loans in each of the two preceding calendar years (2020 and 2021) or at least 200 covered open-end lines of credit in each of the two preceding calendar years (2020 and 2021).
2. Regulatory Alert 22-RA-02: Submission of 2021 Home Mortgage Disclosure Act Data
Credit unions located in metropolitan areas that engage in certain types and volumes of residential mortgage lending, and that had assets exceeding $48 million as of December 31, 2020, must file a report this year on mortgage loan applications received during 2021. Credit unions subject to Home Mortgage Disclosure Act (HMDA) requirements in the calendar year 2021 must submit loan/application register (LAR) data to the Consumer Financial Protection Bureau (CFPB) by March 1, 2022.
3. Letter to Credit Unions 22-CU-02 NCUA’s 2022 Supervisory Priorities
NCUA’s Letter to Credit Unions (LTCU) 22-CU-02 identifies the agency’s supervisory priorities for 2022, which include:
- Credit Risk Management
- Information Security (Cybersecurity)
- Payment Systems
- Bank Secrecy Act Compliance and Anti-Money Laundering/Countering the Financing of Terrorism
- Capital Adequacy and Risk-Based Capital Rule Implementation
- Loan Loss Reserving
- Consumer Financial Protection
- Loan Participations
- LIBOR Transition
- Interest Rate Risk
Exam Program Updates:
- NCUA Connect & MERIT
- Recording of Official Meetings
4. CFPB Summary re: Notice and Request for Comment Regarding CFPB’s Inquiry into Buy-Now-Pay-Later (BNPL) Providers
In December 2021, the Consumer Financial Protection Bureau (CFPB) opened market monitoring orders, inquiring into Buy-Now-Pay-Later (BNPL) products in the United States to gain information about the size, scope and business practices of the BNPL market. The information will help the Bureau better understand how consumers interact with BNPL providers and how BNPL business models impact the broader e-commerce and consumer credit marketplaces.
Comments are due on March 25, 2022.