TIP: The Federal Reserve System’s quarterly “Consumer Compliance Outlook” is a helpful publication dedicated to consumer compliance topics. It typically includes several articles, plus a federal regulatory calendar.
Credit union compliance professionals who don’t already receive this publication may want to sign up to get an email notification when a new issue is released.
The first issue of 2025 includes three articles that credit unions may want to review:
- 2024 Aggregate Supervisory Data for Institutions the Federal Reserve Supervises. The Federal Reserve System is the primary federal regulator for state member banks. This article lists: 1) the top consumer law violations Federal Reserve examiners have identified at those banks; 2) the top categories of consumer complaints the Federal Reserve receives; and 3) the top Matters Requiring Immediate Attention (MRIAs) and Matters Requiring Attention (MRAs).
The Federal Reserve does not supervise credit unions, of course, but this data can still help you identify common compliance issues and the kinds of complaints that consumers – including your members – might have.
Among other things, this article covers the most frequent violations of the Home Mortgage Disclosure Act (HMDA) and Reg. C. Those laws require certain financial institutions to collect, record, report, and disclose information about their mortgage lending activity. The article goes on to discuss the common procedural breakdowns that may contribute to the root causes of HMDA violations.
- Top Federal Reserve System Compliance Violations in 2024: Home Mortgage Disclosure Act. This piece provides sound practices and other strategies that any financial institution, including a credit union, can use to enhance its HMDA data collection and reporting practices.
For information on HMDA compliance, please see The League’s ii Release No. B017, plus other resources listed on our Compliance Topics A to Z page “Reg. C – Home Mortgage Disclosure.”
- Record Retention Reference Guide for Federal Consumer Protection Laws and Regulations. Most federal consumer protection laws and regulations require credit unions (and others) to retain records of compliance for a specified period. The Federal Reserve has updated this chart (which it first issued in 2018) to give users a high-level summary of the retention requirements for select federal consumer protection laws and regulations.
The chart is intended to provide a quick overview but is not a substitute for reviewing the applicable statute or regulation. Other state and federal laws may also impose record retention requirements. The League’s Compliance Topics A to Z page on “Record Retention” offers helpful links. Also, keep in mind that the NCUA is considering changes to its record retention guidelines. The League submitted a comment letter last summer on an NCUA request for “comments on ways the agency can improve and update its records preservation program regulation and accompanying guidelines.”