NEWS: The following ii Releases are new or recently updated. Revised text is indicated by blue text in each ii Release. We will not announce individual updates or update the revision date when we only make formatting or other insignificant changes. For example, we will not publish a revision note or update the revision date when we add a hyperlink, fix a typo, or make slight clarifications to the text. As always, we recommend that credit unions access ii Releases directly from the internet when needed so that you can be sure you are viewing the most recent version. Updates to the ii Releases are posted daily on our website here.
May
ii Release No. B083 – Reg. B – Small Business Lending Rule, has been updated to reflect the CFPB’s announcement that it will not prioritize enforcement of its small business lending rule. See this Compliance Courier for details.
ii Release No. 0028 – Conflicts of Interest, and
ii Release No. 0178 – Oversight and Enforcement Powers of the Office of Credit Unions, have been updated to reflect minor amendments to the wording of regulations by the Wisconsin Office of Credit Unions.
ii Release No. B027 – Business Loans, has been updated to reflect the Wisconsin Office of Credit Unions’ amendments to its member business lending rules, as explain in this Compliance Courier.
April
ii Release No. 0159 – BSA: Customer Identification Program and Customer Due Diligence, has been revised to correct information about the obligations that financial institutions have to identify the “beneficial owners” of legal entities that may own some or all of a legal entity that is opening an account, under the federal Customer Due Diligence regulations.
ii Release No. B083 – Reg. B – Small Business Lending Rule, has been revised to indicate that the CFPB plans to start a new rulemaking process to revise its small business lending rule. Those revisions may substantially change the compliance requirements of this rule. For details, see this Compliance Courier.
ii Release No. B080 – Payday and Vehicle Title Loans, has been updated to reflect a recent CFPB announcement that it will not prioritize enforcement or supervision actions of its payday lending rule. In its press release, the CFPB said that it is “is further contemplating issuing a notice of proposed rulemaking to narrow the scope of the rule.”
March
ii Release No. B044 – Motor Vehicle Liens, to reflect that as of Jan. 5, 2025, all “non-exempt” secured parties that are listed on Wisconsin motor vehicle titles must release their lien electronically. Secured parties that filed 48 or fewer liens on Wisconsin titles in the previous calendar year are exempt under the DOT regulations. They can release liens electronically or provide the signed release on the title/paper lien release. Secured parties that filed more than 48 liens on Wisconsin titles in the previous calendar year are “non-exempt,” which means that they are subject to the electronic lien release requirements. The DOT has clarified that “regardless of if you are holding an electronic or paper title, you will be required to release the lien electronically if you are a non-exempt secured party. Neither a signed title release nor a paper lien release will be accepted.” The League has more information about this requirement, including links to helpful resources, in this Compliance Courier.
ii Release No. B014 – Real Estate Settlement Procedures Act (RESPA), was revised to clarify Wisconsin state law related to the payment of dividends for escrow accounts.
ii Release No. 0191 – Required & Recommended Credit Union Policies, is new. It lists policies that credit unions may be required to maintain, as well as policies that regulators or The League recommend. The new release should be used as a guide and is not an exhaustive list of federal or state laws or regulations that trigger policy requirements. Even where a policy is not explicitly required, credit unions may benefit from board-approved policies on various issues. The release does not include employment-related policies. For guidance on employment practices, policies, and procedures, please consult the credit union’s employment attorney. Note, however, that The League does offer a Model Credit Union Employee Handbook (WCUL #83010) for Wisconsin credit unions with fewer than 50 employees. It is available for purchase via The League’s online “credit union forms” page. Lastly, please note that The Compliance Specialists can help credit unions develop and maintain their policies. For information on Compliance Specialists services, visit the Compliance Specialist Program page on our website or contact Laura Nelson, the program’s director, at lnelson@theleague.coop or (608) 640-4061.
ii Release No. 0190 – Recurring Credit Union Compliance Obligations, has been updated to add information on annual policy review requirements for federal credit unions that use derivatives (as defined in the NCUA Rules & Regs.).
Join a member of The League’s compliance team as they lead a discussion on the latest changes in regulations and need to know information to keep your credit union in compliance. You can find more information or register on our website.