By The Way
The By The Way newsletter is a great way to keep Kentucky credit unions informed of the latest updates in governmental affairs, compliance and regulations, education and training. In addition, By the Way highlights the difference credit unions are making on a daily basis.
Credit Union News
Wendell Lyons, KCUL, Garth Griese, CEO-Service One Credit Union, and Tim Root, VP Marketing-L&N FCU, had the opportunity to play golf with Senator Rand Paul at the Bowling Green Country Club, Bowling Green, KY.
On November 8, 2017, Fort Knox Federal Credit Union hosts State Representative Bart Rowland, Chairman of the House Banking and Insurance Committee at their Dixie Branch location in Elizabethtown, KY.
Powerful Cause. Positive Effect.
To earn the support of lawmakers, credit unions need to stand together and send a united message that our 110 million members matter. CUNA GAC is where you will:
- Network with nationwide credit union leaders
- Attend keynote sessions from thought leaders in politics, business, and media
- Explore regulatory compliance and advocacy issues in breakout sessions Advocate for credit union priorities during league-organized hill visits
- Connect with exhibitors in the credit union movement's largest exhibit hall
George W. Bush to Speak at CUNA GAC
AN EXCLUSIVE CONVERSATION WITH PRESIDENT GEORGE W. BUSH
Our 43rd president and founder of the George W. Bush Presidential Center will discuss the challenges facing our nation in the 21st century and the power of freedom at the CUNA Governmental Affairs Conference.
Join us February 25 - March 1, 2018.
New CUNA.org Website Launch Scheduled for this Week
CUNA has been hard at work a new website for you! They’ve been listening and have designed a site that features a better overall experience, relevant content and a fresh look. Their planned launch date is December 1st.
Your username and login for cuna.org will be the same.
You'll be able to continue to get your news content from news.cuna.org.
CUNA 2018 Credit Union Hero of the Year Award Nominations Open
Nominations are open for the CUNA 2018 Credit Union Hero of the Year Award.
“We seek to recognize those who are making significant contributions that advance the credit union movement,” says Ann Peterson, CUNA’s vice president of publishing. “We’re looking for people who have truly invested their hearts and souls into creating a lasting impression not only at their credit union but on behalf of all credit unions.”
The nominees should exemplify the credit union philosophy of “people helping people,” go the extra mile to make a difference in their communities and demonstrate their service, advocacy, and commitment to the credit union movement. The 11th annual Credit Union Hero of the Year Award is sponsored by CSCU.
“We invest annually to sponsor the Credit Union Hero of the Year Award because it gives us the opportunity to celebrate credit union leaders who live the credit union philosophy every day,” says Jennifer Bryant, vice president of marketing at CSCU. “We are pleased to partner with CUNA and look forward to celebrating all the 2018 nominees and their commitment to service.”
The deadline for nominations is Dec. 8.
- Are credit union system employees or volunteers;
- Are working or retired;
- Are unsung heroes, going above and beyond to promote credit union philosophy;
- Take a stand or exhibit a firm belief in credit union values;
- Show dedication to credit union principles; and
- Make a difference in the local community.
Those selected as Credit Union Heroes will be featured in the March issue of Credit Union Magazine.
Mark your calendars for these 2018 education and training opportunities! Stay tuned as we confirm dates for our other popular events.
New Manager Boot Camp
BSA/AML Regional Workshop
Bankruptcy & Collections Workshop
Volunteer Leaders Conference
84th Annual Meeting & Convention
December 12-19, 2017
Your website is your most important branch but if it’s not working as effectively as it should be, existing and potential members might choose to do their banking elsewhere. This online workshop will provide both practical advice and best practices from digital experts – exploring topics ranging from user-experience, design, compliance, analytics tracking and more.
During this e-School, you will:
- Discuss must-have and nice-to-have components of a “digital branch”
- Explore best tactics to compete with national competitors and larger banks
- Explore how to maximize and understand your website data
- This is a great opportunity to gain real-world experience for addressing common website problems, planning your own website redesign and developing a phased plan for your digital branch.
This eSchool is endorsed by CUNA Marketing & Business Development Council Conference.
“Your Data Belongs in Your Strategic Plan”
by Jeff Rendel, Certified Speaking Professional
“We could double our assets without adding one member,” a CEO of a near-billion dollar credit union shared. “The answer lies in knowing how our data helps us create new systems of value for our members. We are, strategically, converting data into a practical competitive advantage.”
“Big Data” carries a number of definitions, most describing large sets of information that may be examined computationally to reveal patterns, trends, and associations. Big Data helps Amazon know that your research on patio cover materials, purchases of sports collectibles, and partiality to 80s rock bands makes you a prospective candidate for a home brewing kit.
Where Big Data holds out great promises for credit union marketing, i.e. the ability to enrich target marketing, forecast next best products for members, and generate more efficient marketing budgets; it also yields great strategic value. Big Data – better said, Your Data, can create unrivaled value for your members. Your Data produces more than the next best purchase or transaction; it initiates models for loyalty and lifetime value from your members.
Knowing what its data could deliver, the above credit union established a strategic objective to “Understand, harness, and act upon in-house and business-partner supported data.” Rather than purchase add-on analytics software, the credit union worked with its core processor, CRM partner, and card services partners to produce business intelligence for marketing, process, and service improvements. The data existed; the credit union just needed specific support from its partners. “Our data gave us vital information about our members and operations. Our members are better served because of what we know, and what we act on; and, their credit union performs better with our real-time insights to operations,” per the CEO. The lion’s share of this credit union’s growth is coming from its existing sets of members.
A second credit union sought to shift its focus from growth through indirect lending to direct marketing. The scale required to compete in indirect lending was more than this credit union could support. It also realized that just one-third of its members were traditional members; the remaining indirect members were “top line customers, for all intents and purposes; and, our traditional members were three times as profitable,” said the CEO. Working with its CRM partner, the credit union learned which members were most profitable and loyal; and, it developed an original member acquisition, development, and relationship model. While still involved in indirect lending, the credit union’s growth now derives, largely and strategically, from direct marketing and business development.
All credit unions are in the information business. Your Data, already owned, can create value for your members and belongs in your strategic plan. Your Data provides information about longer-term member loyalty and relationships. It offers much more than what will trigger the next purchase; it offers insights and opportunities to greater lifetime value. It creates utility for your members and, as a result, worth for your credit union. Include Your Data as a documented part of your strategic plan.
Jeff Rendel, Certified Speaking Professional and President of Rising Above Enterprises, works with credit unions that want entrepreneurial results in leadership, sales, and strategy. Each year, he addresses and facilitates for more than 100 credit unions and their business partners.
The first student-operated credit union powered by Ashland Credit Union is now open for business.
Thirteen Fairview High School students celebrated the Grand Opening of Eagle Street Credit Union Tuesday, September 12th.
Students in the school’s Financial Literacy class are getting hands-on experience with positions such as tellers, new accounts, loan officers and marketing through the new school Credit Union.
Participants submitted a resume and completed an interview with ACU. Students have been cross-trained in all areas of operation, privacy, and security. ESCU offers students and staff the ease of accessing checking, savings and mini loans at lunch right on campus. The Credit Union is overseen by Fairview’s Financial Literacy teacher Angie Reihs.
For more information about ACU’s new student CU, contact Candace Stanley, Business Development Specialist, at 606.329.5454.
A cool November day was transformed into a Winter Wonderland, as Commonwealth CU hosted the first evening of The 37th Annual Candlelight Tradition in Downtown Frankfort.
This event, the official kickoff to the holiday season in the Capital City, was presented by the credit union. Holiday magic was in the air with a Polar Express Train Experience and an appearance by the man of the season, Santa Claus!
This event also included a silent auction and donation centers for the benefit of both a local women's facility and a cancer research fund. Guests also had the opportunity to take part in the Enter to Win Giveaway for three fantastic prizes.
Doe Run Federal CU and Home Plate Restaurant Co-Sponsor 3rd Annual Veterans' Dinner
The 3rd annual co-sponsored Veteran’s dinner was November 8, 2017, at the Home and Garden Exhibit building at the Meade County Fairgrounds for the Veteran members of Doe Run Federal Credit Union.
Many of the Veterans came early to visit among one another. Each Veteran and family member was welcomed by the staff of Doe Run Federal CU. The Pledge of Allegiance was led by Daryl Durbin. Ronald Mucker led the blessing over the food. The Veteran members and their family also enjoyed dinner by Home Plate Restaurant. They also enjoyed cakes made by Yum Yum Bakery, decorated very patriotic.
Debbie Allen, Manager of Doe Run Federal CU welcomed each Veteran and their family member. The evening was filled in honoring each Veteran, their achievements, courage, dedication and many sacrifices in defending our country. She also went on to thank the family member for what they have done to live through difficult times to keep the home fires burning.
Cletis Evans (formerly from Meade County and a graduate of Meade County High School) with Honor Flight Bluegrass was the guest speaker for the event. He spoke of how important it is for each Veteran to get to Washington D.C. through this program. He spoke of the highlights of getting each and every Veteran to get to tout the monuments and the traffic coming to a complete stop for buses to get the Veterans to where they should be, with full respect and appreciation. The Veterans in attendance at the dinner will each receive information very soon from the Honor Flight Bluegrass program.
The Veterans that wished to share some of their highlights of being in the armored services, shared stories amongst the crowd of guests.
Door prizes were given to: Earl Murphy, Ronald Mucker, Martin Webb, Glenn Crawford, Willard Andry, Linus Prochaska and Donald J. Keys.
Debbie Allen closed the evening by thanking the Veterans once again for their courage, pride, determination, selflessness, and dedication to duty…all the qualities needed to serve a cause larger than one’s self.
This event was made possible by two great local businesses, Home Plate Restaurant and Doe Run Federal CU, businesses that truly care about the folks in their community.
Fort Knox Federal, in partnership with the Danville Fire Department, will hold its 3rd annual toy drive on December 1st, 2017. The event will be held at its Danville branch location, 312 Skywatch Drive, Danville, KY and will feature refreshments from 11am – 5pm and photos with Santa from 1pm – 5pm. The Danville Fire Department will also be on hand during the event to accept cash donations and provide tours of the fire truck.
Anyone is welcome to bring a new, unwrapped toy to Fort Knox Federal’s Danville Branch from Dec. 1st through Dec. 19th. Items received after the Dec. 1st event will be delivered to the Danville Fire Department on December 20, 2017.
“The Toy Drive is such a fun celebration and an important way to give back,” said Gail Gottshall, Fort Knox Federal’s Danville Branch Manager. “I love being able to serve our community and improve members’ financial lives through Fort Knox Federal’s involvement and dedication to its ‘people helping people’ philosophy.”
Fort Knox Federal Honored for USA Cares Support
Fort Knox Federal Credit Union was honored to be recognized for its partnership with USA Cares and ongoing contributions to help military veterans last month at the 2017 USA Cares Gala in Louisville, Kentucky. Over the years, Fort Knox Federal and its members have donated over $325,000 to USA Cares, supporting their mission to assist military families in crisis. These funds have directly helped more than 100 military families pay their utility bills, buy food and fuel, as well as assist with housing costs.
“Fort Knox Federal Credit Union has been such a wonderful partner over the years that we wanted to express our appreciation,” said Hank Patton, USA Cares Executive Director. “Fort Knox Federal continues to demonstrate a valuable commitment to our mission of supporting military families when they need it most; because of this, Fort Knox Federal has established themselves as one of our strongest partners and we cannot thank them enough.”
USA Cares originally started as a grassroots partnership of the Fort Knox Chapter of the Association of the United States Army, Kroger Food Stores – Mid-South Division, and WAVE-3 TV, the NBC affiliate in Louisville. Fort Knox Federal was one of the earliest supporters of USA Cares and continues to give towards their mission along with many of the Credit Union’s generous members.
“We’re proud to partner with USA Cares to support veterans and their families,” said Ray Springsteen, Fort Knox Federal President and CEO. “Fort Knox Federal is dedicated to improving our members’ financial lives and supporting community organizations like USA Cares is part of our ‘people helping people’ philosophy.”
A portion of the donations to the organization were dues paid by Fort Knox Federal for new credit union members who joined as part of the USA Cares Patriot Club field of membership. In 2014, USA Cares launched the Patriot Club which is open to anyone wishing to support the organization’s mission and donate to supporting military families. All dues and gifts to the Patriot Club go directly to sustain USA Cares’ support of military families.
For more information about USA Cares or Fort Knox Federal, please log on to www.usacares.org or www.fortknoxfcu.org, respectively.
Fort Knox Federal Credit Union is pleased to welcome Leigh Sherrard as its Ring Road Branch Manager. Sherrard was born and raised in Elizabethtown and brings both retail banking and small business lending experience to the credit union.
With her dedication to serving members and the community, her hometown credit union was a natural fit. "I am thrilled to be part of the Fort Knox Federal family and the Ring Road Team! We do what we say we'll do, which is to improve our members' financial lives," says Sherrard. "For me, being part of the credit union's community involvement and witnessing the impact we're making is indescribable."
Sherrard and her husband have five beautiful children and can often be found at a local sporting complex or field. Her four oldest graduated from the Elizabethtown Independent School District and her youngest is currently attending Morningside Elementary. Two of her children are enrolled at Elizabethtown Community and Technical College (ECTC) and one recently graduated Basic Training for the Air National Guard and will be attending Eastern Kentucky University. She is excited to be working in her hometown area again and looks forward to reconnecting with local organizations and representing Fort Knox Federal Credit Union in the community.
"We're excited to welcome Leigh to Ring Road. Her knowledge and skills will serve our members and community well," says Becky Ates, Executive Vice President of Fort Knox Federal Credit Union. "Everything we do at Fort Knox Federal is for our members and it's great to have someone who knows Elizabethtown inside and out leading this branch."
During the fall months this year, employees and members of L&N FCU donated over $10,000.00 to charitable causes.
Employees and volunteers participated in the 2017 Heart Walk and raised $3,657.24 to benefit the American Heart Association.
They also participated in the 2017 Light the Night Walk and raised $3,859.48 to benefit the American Leukemia and Lymphoma Society.
Over $2,500.00 was raised to help communities devastated by recent hurricanes.
Expressing appreciation and gratitude to the men and women who serve our county is important to L&N. This year, L&N joined forces with major organizations to help support Rally Point-Kentuckiana in making life better for Veterans. Through Rally Point, a variety of opportunities and resources are made available to Veterans in the community. A few include:
- A Resource/Job Fair exclusively for Veterans with 58 companies present.
- A Benefit Concert with Country Music Star Trace Atkins with over 3,000 attendees that raised over $100,000.00.
L&N’s own, PJ Moore, also served as a board member for the origination. To learn more about Rally Point Kentuckiana visit: www.rallypointkentuckiana.org
As Director of Community Development, PJ Moore devotes much of her time in the community sharing the benefits and advantages of choosing L&N Federal CU for financial services. In addition to representing L&N at various chambers, business associations, and networking groups, she is incredibly engaged in groups and associations for real estate professionals.
Recently, PJ was recognized as Affiliate of the Year by the Greater Louisville Association of Realtors (GLAR). The Affiliate of the Year Award is selected by GLAR’s outgoing president and given to an affiliate member who positively impacted GLAR during that year.
Throughout the month of October, Kentucky Employees Credit Union members and staff engage in various fundraising activities, including creating and producing custom pink breast cancer shirts and pink KECU items available for purchase, custom pink breast cancer awareness debit cards, an employee pumpkin painting and voting, and an annual collegiate wreath raffle. All proceeds generated from pink activities in October are donated to Making Strides Against Breast Cancer.
As title sponsor of the Frankfort Area Chamber of Commerce 2017 Reality Store, over 700 students gathered at Thorn Hill Education Center to play The Game of Life! Participants, made up of 8th grade middle school students across Franklin County, played the game of life to learn about the real-world relationship between education and career opportunities, lifestyle choices and monthly budgets. Reality Store is a hands-on interactive educational experience where each student is assigned an occupation and monthly income based on their grade performance in school, and learn how to navigate through life, dealing with both expected and unexpected expenses. Several KECU team members volunteered to staff the game and engage students one-on-one. In addition to the experience, students received KECU bags, pencils, and a Money Rules by Jean Chatzky book.
For November’s Military Family Appreciation Month, KECU has launched a Feed the Need campaign, to collect items for sending overseas to a local National Guardsman on deployment, as well as food items for local military families in need. Members and staffers have donated and placed in the turkey box to support the Feed the Need effort.
You may have heard that Members Choice Credit Union is the preferred partner of Our Lady of Bellefonte Hospital…well, that’s worthy of a celebration. Members Choice Credit Union welcomed local representatives and hospital employees to open its newest branch in Bellefonteon Tuesday, November 14th.
“Our Lady of Bellefonte Hospital has been great partners of ours for several years. They were all so enthusiastic and supportive of the idea for Members Choice CU to come back on campus. I’m thrilled that so many were able to join us on this special day and celebrate the growth of our partnership” said Cheryl Deborde, MCCU’s President/CEO.
The grand opening event was well attended; the Credit Union estimates nearly 150 guests came and went throughout the day, enjoying sweet treats from Mary’s Kitchen and Catering, and touring the newly renovated office.
“I’m incredibly pleased with the success of the grand opening,” said Perry Blake, Project Manager of Members Choice. “We opened new accounts, met several employees, and had a great day. Members Choice is truly excited to be a part of the hospital community again.”
Service One Credit Union helped the Western Kentucky University Hilltopper Athletic Foundation by selling raffle tickets to win a 2017 Red Corvette! Service One sold 356 tickets! The most sold by any WKU affiliated group (not Alumni, Greek or Sports) selling raffle tickets.
The Big Red Vette Raffle is an annual fundraising event sponsored by the Hilltopper Athletic Foundation and WKU Athletics. Currently, in its 24th year, the Raffle has raised over $2 million towards WKU student-athlete scholarships. Raffle tickets are sold for $10 each. The winner is drawn live at halftime of the final Hilltoppers home football game each year and has the choice between accepting the car or $35,000 cash. The 2017 drawing took place at halftime of the WKU vs. Middle Tennessee State University football game on November 17, 2017.
On Saturday, September 23, 2017, Service One Credit Union hosted its 4th annual community shred day at the 1609 Campbell Lane Branch. This three-hour event was open to the community. It was well attended, with the community securely shredding nearly 3 tons of paper. The paper shredded was recycled, saving 51 mature trees, 1,200 gallons of oil, 21,000 gallons of water and nine cubic yards of landfill space. Paper disposal services were provided by Land Shark Shredding
Minimum donations of $5 were requested to benefit The Center for Courageous Kids; a non-profit center based in Scottsville, KY which supports children with life-threatening illnesses. This event raised $863 for this great organization. Service One supplemented the donations received to contribute a total of $1,000 to The Center for Courageous Kids.
“It was a pleasure individually meeting those who came out to Service One’s Shred Day,” said Garth Griese, Service One President/CEO. “Service One is dedicated to helping our members realize their financial dreams. Having shred day events like this is one of the many ways Service One supports our membership and our community’s financial wellness.”
The Center for Courageous Kids (or CCK) welcomes children with life-threatening conditions from all across the country for a week or weekend of medically supervised fun, friendship, respite, and silliness – all free of charge. Operating solely on donations, the tremendous opportunities that CCK provides each child living with medical challenges are made possible by generous contributions and donations from individuals, corporations, healthcare partners, foundations, and the community at large. Find out more information about CCK by visiting: http://www.courageouskids.org/
The CFPB has announced the following threshold changes, which will become effective January 1, 2018.
- Transaction exemption thresholds under Regulation Z (Truth in Lending) and Regulation M (Consumer Lending) will be increased to $55,800 (from $54,600 in 2017).
- Thresholds for loans exempt from special appraisal requirements for higher-priced mortgage loans (HPMLs) will be increased to $26,000 (from $25,500 in 2017).
- The maximum allowable charge that a consumer reporting agency may charge a consumer for making a disclosure to the consumer of the contents of the consumer's credit file will remain unchanged during 2018 ($12).
The Federal rules of Bankruptcy procedures dealing with requirements and timing of a Proof of Claim are changing on December 1, 2017.
Currently, Bankruptcy Rule 3002 generally requires a proof of claim in a Chapter 7,12, or Chapter 13 case to be filed no later than 90 days after the first date set for the meeting of creditors.
The new bankruptcy rule change will require a proof of claim to be filed no later than 70 days after the date the bankruptcy case is filed. This is certainly a decrease in the amount of time permitted for filing a proof of claim.
Attachments that are generally required, such as a note, mortgage or security agreement can be filed as a supplement to a credit union's claim no later than 120 days after the date the bankruptcy is filed.
The new rules also clarify that secured creditors must file a Proof of Claim for the claim to be allowed, but the creditor's security interest is still valid even if the creditor fails to file the proof of claim.
A credit union should receive a Notice from the Bankruptcy Court advising the credit union that the debtor has filed either a chapter 7 or a Chapter 13 bankruptcy. The notice in a chapter 13 bankruptcy will indicate the deadline for a creditor to file a proof of claim.
In a chapter 7 bankruptcy, the notice will either provide a deadline for filing a proof of claim where there are assets available to pay creditors or where there are currently no assets available to pay creditors, will indicate that a creditor should not file a proof of claim unless they receive a notice from the court to do so. If it later appears that assets are available to pay creditors the bankruptcy clerk will send another notice indicating that a creditor may file a proof of claim and the deadline for filing the claim.
The NCUA issued a checklist for credit unions to voluntarily use in assessing its diversity and inclusion practices in a Letter to Credit Unions (16-CU-05) last year. Two-thirds of participants in last week’s NCUA diversity webinar said they were unaware NCUA offers a self-assessment checklist, and 64.3% said they do not have a policy on diversity and inclusion.
A recent CUNA CompBlog post highlights several quick facts about the checklist that can be handy to credit unions, particularly CEOs, Human Resources departments and board members.
- It’s a voluntary annual assessment;
- The checklist has no impact on exams or a credit union’s CAMEL rating;
- It takes about one hour to complete the 28 questions;
- While the assessment measures current diversity policies in your credit union, for those credit unions without current policies it provides a baseline of practices to implement; and
- The data obtained from the assessment is reported anonymously and in aggregate.
There are five areas of focus for the questions:
Is there an organizational commitment to diversity and inclusion by leadership?
Does the credit union proactively implement employment practices that expand outreach efforts to minorities, women, and other diverse individuals?
Does the credit union consider supplier diversity as part of its procurement and business practices?
Does the credit union promote transparency of its diversity and inclusion practices?
Does the credit union monitor and a assess diversity policies and practices on an on-going basis?
Credit unions wishing to take part in the voluntary assessment can do so through Dec. 31.
Q: I read the recent blog post about W3C's Web Content Accessibility Guidelines (WCAG) 2.0 being the de facto standard for accessible websites under the ADA in the absence of DOJ regulations addressing this issue. But, what conformance level should we shoot for – A, AA, or AAA?
A: The WCAG 2.0 "success criteria" are categorized according to three levels: A, AA, and AAA.
Level A – provides the most basic web accessibility features
Level AA – addresses the most common barriers for disabled users
Level AAA – delivers the highest level of web accessibility
Conformance at a higher level indicates conformance at lower levels, i.e. conformance to Level AA necessarily implies conformance to Level A.
As for which conformance level you should strive to meet, you may want to follow the Architectural and Transportation Barriers Compliance Board's ("Access Board") lead. The Access Board's standards and guidelines for federal agency websites conform to WCAG 2.0's Level A and Level AA success criteria and conformance requirements. So, there's a good chance that the DOJ may do the same when it formulates its web accessibility regulations. See CUNA leaders meet w/ DOJ officials on ADA guidance
Stay tuned for more information on the ADA, and click here for the W3C's quick reference guide to the WCAG 2.0.
CUNA’s Final Rule Analysis of the Consumer Financial Protection Bureau’s (CFPB) short-term, small-dollar loan rule is now available. CUNA prepared the analysis so credit unions can start to digest the rule and figure out how it will affect small-dollar lending at their institution.
The rule was finalized Oct. 4, and contains a number of CUNA-backed improvements over the originally proposed version.
The final rule exempts loans issued in accordance with NCUA’s Payday Alternative Loan (PAL) program, as well as most accommodation loans.
Other types of loans specifically exempted:
- Certain purchase money security interest loans;
- Real estate secured loans (including personal property used as a dwelling);
- Credit card accounts;
- Student loans;
- Non-recourse pawn loans;
- Overdraft services and overdraft lines of credit;
- Wage advance programs; and
- No-cost advances.
Credit unions making short-term loans with terms of less than 45 days that require the consumer to pay all or most of the debt at once will still be impacted by the rule, and thus will be subject to strict underwriting requirements.
Long-term balloon loans are also within the scope of the rule, as are high-cost loans (with an annual percentage rate that exceeds 36%) that also have a leveraged payment mechanism in place that allows the credit union initiate a transfer of money from the member’s account to satisfy the loan obligation.
Credit unions originating these types of loans must conduct an ability-to-repay test to determine upfront that borrowers can make his or her payments for major financial obligations, required payments under the loan and meet basic living expenses during the term of the loan and for a period of time thereafter.
In addition, the credit union must also consider the member’s previous borrowing history related to covered loans.
Finally, the rule prohibits a credit union from making repeated attempts to withdraw payment from a member’s account after its second consecutive attempt to do so has failed due to lack of sufficient funds. The rule also imposes a number of new disclosure requirements.
Most of the rule becomes effective 21 months from the date of publication in the Federal Register.