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2013 Compliance Changes

2013 Compliance Changes. 2013 Changes. Minor disclosure changes IRS reporting for NRAs ATM fee notices New BSA forms Mandatory escrow accounts for HPMLs Remittance transfer disclosures Credit card access rule. Disclosure Changes. Effective January 1, 2013

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2013 Compliance Changes

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  1. 2013 Compliance Changes

  2. 2013 Changes Minor disclosure changes IRS reporting for NRAs ATM fee notices New BSA forms Mandatory escrow accounts for HPMLs Remittance transfer disclosures Credit card access rule

  3. Disclosure Changes • Effective January 1, 2013 • List the CFPB as the contact regulator on certain disclosures, including: • Risk based pricing notices • Credit card application disclosures • Open-end account opening disclosures

  4. IRS Reporting for NRAs • Effective January 1, 2013 • Requires the reporting of deposit interest to the IRS for nonresident aliens • Rules: • Financial institutions (including credit unions) must file IRS Form 1042-S for interest (of $10 or more) paid to a nonresident alien. • The rule specifically covers nonresident aliens who are residents of a country with which the U.S. has an information-sharing agreement

  5. New BSA Forms Effective April 1, 2013 Electronic filing of BSA forms required in June 2012 Revised forms for CTRs and SARs required on effective date

  6. ATM Fee Disclosures Effective March 26, 2013 Big win for credit unions and banks Eliminates external fee notices on ATMs Screen notices still required Reduces frivolous lawsuits

  7. Mandatory Escrow Accounts Effective June 1, 2013 Applies to Higher-Priced Mortgage Loans Requires mandatory escrow accounts for the first five years

  8. Remittance Transfer Disclosures • Effective October 28, 2013 • Applies to foreign remittance transfers • Requires a remittance transfer provider to provide a consumer sender: • Awritten disclosure provided prior to the initiating a transaction that includes the actual exchange rate, fees and taxes, and the amount of currency to be received by the recipient • A written receipt that includes the prepayment disclosure, information about error resolution, provider and regulator contact information, and the availability of the funds upon receipt • Small providers are exempt

  9. Credit Card Access Rule Effective November 4, 2013 Eases “independent ability to repay” underwriting rules from the credit card act for consumers over 21 Household income can be used to qualify for a credit card

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