3 summaries look at letter, alert and accounting bulletin
Oct. 18, 2016 -- Three new summaries – outlining a regulatory alert, letter to credit unions and an accounting bulletin, all from NCUA – have been posted to the NASCUS website. All three summaries are available to NASCUS members only.
The regulatory alert summary outlines the agency’s September item concerning the “Department of Defense’s Interpretive Guidance on Military Lending Act Limitations on Terms of Consumer Credit Extended to Service Members and Dependents.” According to the alert (16-RA-06), the guidance clarifies (among other things):
- Determining a person’s covered borrower status;
- Exercising a statutory right to take a security interest in a member’s account;
- Timing and delivering required disclosures; and
- Identifying fees which can be excluded when calculating the military annual percentage rate for credit card accounts
The “letter to credit unions” summary focuses on LTCU 16-CU-07 (issued this month) – “Military Lending Act Examination Approach” -- in which NCUA states that its examiners will accept credit unions’ “reasonable and good faith efforts” to comply with the Military Lending Act (MLA) rules.
The summary of the September-issued accounting bulletin (16-1) – the first in two years from the agency – reports that NCUA has concluded that a credit union is permitted to use Private Company Council (PCC) alternative accounting reporting options when preparing Call Reports for filing with the agency.
Summary/16-RA-06: Department of Defense’s Interpretive Guidance on Military Lending Act Limitations on Terms of Consumer Credit Extended to Service Members and Dependents
Summary/LTCU 16-CU-07: Military Lending Act Examination Approach
Summary/Accounting Bulletin 16-1: PCC Accounting