Consumer Financial Protection Bureau (CFPB) 

CFPB Released a Research Report on Cash-Out Refinances and Paydown Behavior of Non-Mortgage Debt Balances 

In a recent research report, the CFPB found that consumers who took cash-out refinances of their mortgages initially saw sharp improvements to their credit scores, followed by a gradual worsening of their scores. However, the scores generally remained above their pre-refinance levels. 

The CFPB's report includes the following key findings: 

• Borrowers gave “pay off other bills or debts” as the most common reason for cash-out refinancing: Each year, from 2014 to 2019, more than 50% of cash-out borrowers responding to the National Survey of Mortgage Originations selected “paying off other bills or debts.” For 2020 and 2021, more than 40% selected that reason. “Home repairs or new construction” was the second-most common reason cited each year. 

• Cash-out borrowers often have different debt profiles than other homeowners: Before the mortgage transaction, mean credit card balances were approximately $4,000 higher among cash-out borrowers, while mean student loan balances were approximately $4,000 lower. Mean auto loan balances were similar in magnitude for both groups of borrowers. 

• Cash-out borrowers had sharp improvements in their debt load and credit scores at the time of refinancing: Cash-out borrowers had large drops in credit card and auto loan balances at the time of refinancing but did not generally experience large drops in their student loan balances. Similarly, cash-out borrowers had sharp increases in their credit scores in the quarter after refinance. Credit card balances and use rates trended back toward pre-refinance levels in the year following the refinance, but they did not in that time increase to the pre-refinance level. Credit scores likewise decreased in the year following refinancing but remained above pre-refinance levels. 

CFPB Report Finds Continued Challenges for Households that Rent 

The CFPB has released two reports looking at data on national rental payments from September 2021 to November 2024. The reports found that the percentage of renters who paid late fees in the last year reached 23% in February 2023; however, that rate declined to less than 14% in November 2024. With this decline, the CFPB’s analysis still found that the median outstanding rental balance rose 60% between September 2021 and November 2024 which suggests an increased financial distress among affected households.  Renters that must pay late fees often pay multiple times during the year with the average fee costing $85. The CFPB found a huge portion of renters who incur an initial late fee struggle to recover.  

CFPB Finds Servicemembers Pay More in Auto Lending Market 

The CFPB has published a report that shows United States servicemembers pay higher costs and face greater financial risks than civilian borrowers when taking out credit to buy a car. With more than 20 million auto loans analyzed that originated from 2018 to 2022, the report revealed that servicemembers have larger loans, make smaller down payments, and ultimately pay higher monthly costs.  

Despite servicemembers paying nearly the same for new and used vehicles as civilian buyers, servicemembers on average pay more in interest and fees than civilians do. The report indicates that military borrowers are less likely to make downpayments, more likely to make smaller downpayments when required, and more likely to make negative equity trade-ins. These borrowers are vulnerable to overreaching lending practices.  

CFPB Updates List of Consumer Reporting Companies 

The CFPB annual list of consumer reporting companies has been released. This list identifies dozens of specialty reporting companies that collect and sell access to people’s data, including individuals’ finances, employment, check writing history, or rental history reports. This list can be used to request consumer reporting data, dispute inaccuracies, and block access to credit reporting data through security freezes. This list also informs consumers about the personal information collected for credit and other consumer reports.  

In the United States, personal financial data is used by a variety of entities when making lending, banking, employment, and housing decisions. Consumer financial data can be collected by and reported to many companies and individuals, which can increase consumer risk, especially when consumers are unaware of it. This annual report allows people to find consumer reporting companies that provide specialized reporting for specific markets that might be relevant to them and provides information on how to dispute inaccurate information.  

In addition to this, the released list also includes the following key information: 

• Consumer reporting companies that share information with casinos 

• Social media, driving data, and other unexpected information can be part of certain consumer reports 

• Under many circumstances, people can receive their credit report for free 

• Hard inquires can lower credit scores 

• Bank account history can affect access to credit 

League InfoSight Highlight: InfoSight360 

In today’s fast-paced regulatory environment, staying compliant is more critical than ever. InfoSight360’s artificial intelligence-powered search will redefine compliance resources by intelligently analyzing all available content across the combined products, providing users with accurate and comprehensive answers to their compliance questions in seconds, all derived from carefully reviewed and vetted content in a secure environment. 

InfoSight 360 is launching in Q1 2025 and will revolutionize the way you manage compliance! Stay tuned for additional details. 

End of Support for Windows 10: What Credit Unions Need to Know 

Microsoft will officially end support for Windows 10 on October 14, 2025. After this date, there will be no more security updates, patches, or technical assistance for the operating system, leaving devices running Windows 10 vulnerable to potential security risks and compliance issues.  

Potential Risks for Credit Unions: 

• Security Vulnerabilities: With no more security updates, devices running Windows 10 will be increasingly exposed to cyber threats. For credit unions, this creates significant risks related to sensitive member data, financial transactions, and regulatory compliance. 

• Compliance Risks: Many financial regulations, such as GDPR, PCI-DSS, and others, require that organizations keep their IT infrastructure secure. Continuing to use unsupported software could result in non-compliance, potentially leading to fines or reputational damage. 

• Operational Impact: As technology evolves, newer applications and services may no longer be compatible with Windows 10. Credit Unions may face difficulties in integrating with modern solutions, slowing down innovation and business growth. 

What Credit Unions Should Do Now: 

1. Plan for Upgrade to Windows 11: Begin planning for the upgrade to Windows 11, which will continue to receive support and security updates. Ensure that your hardware meets the system requirements for Windows 11, as older devices may need to be replaced or upgraded. 

2. Assess and Update Security Policies: Strengthen your security posture by implementing stronger controls, such as multi-factor authentication (MFA), encryption, and endpoint protection, across all systems and devices. 

3. Create a Migration Timeline: Develop a clear timeline for transitioning from Windows 10 to Windows 11, ensuring minimal disruption to your operations. Consider conducting testing in parallel to ensure compatibility with mission-critical applications. 

4. Training and Support: Train your IT teams and end-users to handle the transition smoothly. Providing support and resources during the upgrade process will ensure better adoption and fewer operational issues. 

Chairman Hauptman Appoints Sarah Bang as NCUA Chief of Staff 

CFPB Letter to Washington State Legislature on Barring Medical Bills on Credit Reports 

CFPB Letter to Oregon State Legislature on Barring Medical Bills on Credit Reports 

Dealing With Spam Texts, Emails, and Junk Mail 

Feb. 6, 2025: NCUA Webinar on Supervisory Priorities 

March 2, 2025: CFPB Proposed Rule – Amendments to Regulation V to Limit Data Broker Sales of Personal Information 

July 1, 2025: CFPB and FRB – Reg CC Threshold Adjustments 

July 18, 2025: CFPB – Small Business Lending Data – ECOA 

Oct. 1, 2025: Quality Control Standards AVMs 

Oct. 1, 2025: CFPB: Overdraft Lending: Very Large Financial Institutions (Over $10 billion)

Jan. 1, 2026: NCUA – Succession Planning Effective Date

March 1, 2026: CFPB: Residential Property Assessed Clean Energy Financing (Reg Z) 

April 1, 2026: Compliance Date – CFPB Personal Financial Data Rights for Credit Union’s over $10 billion in assets 

June 19, 2026: NACHA – Fraud Return Reason Code

Dec. 12, 2026: NCUA Simplification of Share Insurance Effective Date 

Who or what is a "bearer"? 

Bearer means one who possesses a negotiable instrument marked "payable to bearer" or indorsed in blank. Under the Uniform Commercial Code (UCC), a promise or order made payable to bearer means the check or money order is: 

1. made payable to the person in possession of the promise or order is entitled to payment; 

2. does not state a payee; or 

3. states that it is payable to or to the order of cash or otherwise indicates that it is not payable to an identified person. 

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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, 

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

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