(Oct. 8, 2021) Three new summaries were posted by NASCUS this week on: An NCUA regulatory alert on credit union credit card data submission to the CFPB; an NCUA letter to credit unions about the expiration of homeowner protection programs during the coronavirus crisis; and NCUA’s proposal to amend its subordinated debt rule to allow for the Treasury Department’s Emergency Capital Investment Program (ECIP).
All of the summaries are available to members only.
On Sept. 29, the NCUA issued a “regulatory alert” (21-RA-09) that essentially put credit unions on notice that they may begin submitting data on credit card agreements with their members, and applying data submission requirements, to CFPB’s “Collect” website, which gathers credit card information. The alert also lists important dates for credit unions to consider when submitting their data.
On Sept. 27, the agency sent a letter to federally insured credit unions (letter 21-CU-09), which outlined “critical information” for compliance with expiring pandemic-era homeowner protection programs. The letter noted several key areas, including the deadline for granting forbearance on mortgage payments. It also outlined steps that credit unions may take to continue providing relief to homeowners, even though several programs had expired.
Finally, on Sept. 23 – because of its monthly meeting – the NCUA Board issued a proposal to amend its new subordinated debt rule to accommodate credit union access to federal investment programs – but making no other changes to the rule taking effect Jan. 1. The proposal, according to NCUA staff, would amend the definition of “grandfathered secondary capital” to include any secondary capital issued to the U.S. government or one of its subdivisions under an application approved before Jan. 1, “irrespective of the date of issuance” (that is, when funds are issued), primarily to benefit low-income credit unions (LICUs).
LINKS:
NASCUS Summary: Navigating and Understanding the End of Pandemic-Era Homeowner Protection Programs
NASCUS Summary: Changes to NCUA Subordinated Debt rule
(Oct. 1, 2021) “Critical information” for compliance with expiring pandemic-era protection programs for homeowners are addressed in a letter to credit unions from NCUA this week.
The letter (LTCU 21-CU-09), sent to all federally insured credit unions, provides lenders and mortgage servicers with the information. Among the key points noted:
- The deadline was Thursday (Sept. 30) to grant forbearance through provisions of the Coronavirus Aid Relief and Economic Security Act (CARES Act). Section 4022 of the act, as amended, the agency noted, provides homeowners with federally backed mortgages the option to temporarily suspend their monthly mortgage payments up to 18 months. Borrowers who have not previously been in forbearance have until Thursday to request assistance.
- 4013 CARES Act loans may be modified – including forbearance – until Jan. 1 without designating the modification as a “troubled debt restructuring” (TDR) under certain criteria. Those include: the loan existed before Dec. 31, 2019; the modification is related to COVID-19; the borrower was less than 30 days past due as of Dec. 31, 2019; and the modification is executed between March 1, 2020 and the earlier of Jan. 1, 2022, or 60 days after the date of termination of the national emergency concerning COVID–19 outbreak declared by the president on March 13, 2020.
- The moratorium foreclosure expired July 31. However, the agency pointed out, the Consumer Financial Protection Bureau (CFPB) recently issued a final rule temporarily amending certain mortgage servicing requirements under Regulation X to assist borrowers affected by COVID-19. “Among other amendments, the final rule establishes temporary special COVID-19 loss mitigation procedural safeguards to ensure that a borrower has a meaningful opportunity to pursue loss mitigation options,” the letter states. It adds that, between Aug. 31 and year’s end, a servicer must meet at least one of the specified safeguards before initiating any judicial or non-judicial foreclosure processes where a borrower became more than 120 days delinquent on or after March 1, 2020.
- Although the eviction moratorium expired Thursday, its aim, the letter notes, is to keep people in their homes even after the home has been foreclosed.
The letter also outlines other homeowner and renter assistance programs, which NCUA said provides nearly $10 billion in assistance to keep owners in their homes. The money may be used, NCUA pointed out, for mortgage payments, utilities, insurance, and other needs.
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