Consumer Financial Protection Bureau (CFPB) 

CFPB Issues Annual Adjustment for Exemption Threshold on Appraisals for Higher-Priced Mortgage Loans 

The CFPB released the annual adjustment to the exemption from the special appraisal requirements for higher-risk mortgage loans in 1026.35. Based on the CPI-W in effect as of June 1, 2024, the exemption threshold will increase from $32,400 to $33,500, effective Jan. 1, 2025. 

CFPB Issues Annual Adjustment to the Regulation Z Exemption Threshold 

The CFPB released the annual adjustment to the Regulation Z threshold exemption found in 1026.3(b). Based on the CPI-W in effect as of June 1, 2024, the exemption threshold will increase from $69,500 to $71,900, effective Jan. 1, 2025. 

CFPB Takes Action Against Arbitration Platform Ejudicate for Deceiving Student Borrowers 

The CFPB has banned the private dispute resolution platform Ejudicate from arbitrating disputes about consumer financial products. Ejudicate has been accused of misleading student borrowers about its neutrality and initiating sham arbitration proceedings. Ejudicate acted as a service provider to Prehired, a company that was shut down by the CFPB in 2023 for illegal lending practices. The CFPB has found that Ejudicate treated borrowers unfairly and was not truthful about its role while hiding that its financial interest was aligned with Prehired. 

In 2022, Ejudicate illegally started arbitration proceedings against consumers who defaulted on loans from Prehired. The CFPB found that Ejudicate harmed borrowers by the following: 

• Falsely claiming to be a neutral arbiter 

• Unfairly attempting to bind consumers to sham proceedings 

• Starting arbitration proceedings without borrower consent 

The CFPB’s order will permanently ban Ejudicate from arbitrating disputes about consumer financial products or services.    

Supervisory Highlights: Auto Finance Special Edition, Issue 35 (Fall 2024) 

The CFPB issued a new edition of its Supervisory Highlights describing the CFPB’s supervisory findings related to wrongful auto repossessions, add-on products, and loan serving breakdowns. 

Key issues found in the Supervisory Highlights include: 

• Consumers encountering difficulties with add-on products. Car purchasers are frequently offered add-on products, such as extended warranties or “guaranteed asset protection” insurance, and sellers charge the borrower an upfront lump sum cost at the loan origination that is bundled into the total loan cost. If a borrower pays off the loan balance early, or otherwise terminates the loan, they are generally eligible for a prorated refund of the prepaid premiums for the unused portion of the loan term. CFPB examiners found subprime auto finance companies charging consumers for optional add-on products that the consumers did not agree to purchase. In other instances, examiners found that, following early termination of a loan, servicers failed to provide refunds or credits to consumers for the unused portion of the product. Examiners also found that servicers required borrowers to make two separate, in-person visits to a dealership to cancel an unwanted add-on product, which prevented consumers from exercising their cancellation rights. 

• Lenders improperly applying payments and wrongfully repossessing automobiles. The exams found servicers wrongfully repossessed vehicles due to service providers failing to cancel orders to repossess vehicles when consumers had made payments or had obtained a loan deferment, loan modification, or extensions that should have prevented repossessions. CFPB examiners also found servicers repossessed vehicles without having a valid recorded lien to the vehicle. Some servicers were also misallocating borrowers’ auto loan payments, such as applying payments to late fees first instead of applying to the loan principal and interest, which resulted in borrowers having to pay erroneous late fees. 

• Lenders gave consumers inaccurate disclosures and placed inaccurate information on borrowers’ credit reports. CFPB examiners found lenders misleading borrowers about the chance to qualify for a low interest rate, when in reality the lowest rate offered was more than double the advertised rate. Servicers were directed to stop using misleading marketing materials designed to bait-and-switch consumers on interest rates. Examiners also found that lenders were knowingly placing inaccurate loan information on thousands of consumers’ credit reports. This included incorrect amounts past due for charged-off accounts, inaccurate dates of when borrowers fell behind on payments, and inaccurate actual payment amounts following a payoff or settlement. In some cases, lenders were relying on inappropriate computer systems that were not designed to report information about auto loans. 

League InfoSight Highlight: Coming in 2025: A New Streamlined Experience with Our All-in-One Platform!

We are excited to share that we are nearing the completion of our integrated platform that brings together the best features of InfoSight, CU PolicyPro, and RecoveryPro. Our team has been working diligently for months to create a seamless experience, and we can't wait to unveil everything the new system has to offer!

One Platform, One Sign-On

No more juggling multiple logins! With our new integrated platform, you can conveniently access all three products with a single sign-on. This streamlined experience will save you time and effort, allowing you to focus on what truly matters.

Customizable Dashboard

We understand that every user is unique, which is why we are introducing a customizable dashboard. Tailor your view to feature the content that is most relevant to you and quickly link to the tools you use most to ensure your workspace is efficient and personalized for your workflow.

Robust Search Capabilities

Finding the right resources just got easier! Our powerful new search feature allows you to simultaneously search across all three products, providing comprehensive results that encompass all available resources. Locating the information you need will be quick and efficient!

Maximizing Your Subscription

Many credit unions are already utilizing at least one of our products, but sometimes don’t realize that they have access to additional products. The new system will showcase results from all available content, ensuring you tap into the full range of resources available to your credit union. If you are not currently subscribed to a specific product, we will provide clear information on how to unlock access and explore all we have to offer.

Introducing Our New Artificial Intelligent (AI) Search Engine

We are especially excited to unveil a state-of-the-art AI search engine designed specifically for our closed environment. This innovative tool draws exclusively from verified content in our system, ensuring that you receive only accurate and relevant information tailored to your needs.

Thank you for your continued support and trust during this exciting evolution of our products. Stay tuned for further updates, and prepare for a new, streamlined experience!

If you have any questions or feedback, please don't hesitate to reach out to our team—we're here to help! You can reach us at info@leagueinfosight.com.

GoWest Credit Union Conversations: Fraud & Risk Management 

Exciting news! The Fraud and Risk Management Conversation is now live!  

Email notifications from “GoWest Online” were sent to former participants of the Risk Management Listserv informing them of a message posted inside the Fraud and Risk Management Conversation. The Risk Management Listserv is now closed, and they have been added to the Fraud and Risk Management Conversation, which is a new tool to connect with other Fraud and Risk Managers! All the benefits of the Listserv will be available, plus much more. 

The new tool can be accessed either from the email by clicking the “View/Comment” button in the emails you receive from Conversations, or by logging in directly. Log into your GoWest Online account, click “My Account” and then “Home” to see the Conversations. 

The new Conversation will allow credit unions to share developing fraud issues with each other along with other risk mitigation strategies. 

October is Cybersecurity Awareness Month 

Employee Retention Tax Credit 

Need Cash Quick? A Payday Loan May Not Be in Your Best Interest 

Recovery Scams Will Follow Hurricane Helene and Milton. Here’s How to Spot Them 

Oct. 16, 2024: CFPB FDX Application for Open Banking Standard-Setter 

Oct. 21, 2024: Comments Due on Financial Data Transparency Act

Oct. 30, 2024: Effective Date - NCUA Final Rule on Fair Hiring in Banking

Nov. 15, 2024: NCUA Comments Due Changes to Call Reports

The Social Security Administration has contacted the credit union asking us to provide contact information on one of our members who has direct deposit of Social Security funds; must we comply with SSA’s request? 

Yes. Generally, a member’s information is protected from government disclosure requests (absent a warrant or subpoena) under the federal Right to Financial Privacy Act. However, the Act includes several exceptions, one of which is applicable to requests for information from the Social Security Administration.   

For your individualized login, select your state below. 

If you have questions about this communication, contact us at 800.546.4465 or via our shared email inbox at compliance@gowest.org.

Have a great weekend!

Your GoWest Compliance Team, 

Copyright © 2023 GoWest Credit Union Association. All Rights Reserved.

Mailing Address:
GoWest Credit Union Association, 18000 International Blvd Ste. 1102, SeaTac, WA 98188, United States
1.800.995.9064

View in Browser | Manage Your Preferences | Unsubscribe