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Compliance Specific News & Resources for GoWest Credit Unions
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Compliance Newsletter

COMPLIANCE HEADLINES

National Credit Union Administration (NCUA)


Register Now for the Planning Retirement with Credit Unions Webinar on May 28 


As part of the Older Americans Month, the NCUA’s Office of Consumer Financial Protection will host a webinar on the importance of preparing for retirement and how credit unions are helping their members get ready. 


A representative from the U.S. Department of Labor’s Employee Benefits Security Administration will outline the retirement resources they have available that can help credit union members prepare. Also, representatives from AmeriCU Credit Union in Rome, New York, will discuss their approach and the types of resources their credit union has available to help their members plan for retirement. 


May 22 NCUA Board Meeting 


The NCUA Board received briefings on the performance of the NCUSIF in the first quarter of 2025 and the NCUA’s Voluntary Separation Program. 


The Share Insurance Fund reported a net income of $79.8 million, a $1.2 million increase from the fourth quarter of 2024. The Fund’s assets increased 3.14% in the first quarter to $23.0 billion from $22.3 billion at the end of 2024. The equity ratio remains at 1.30% as of end of 2024. 


There were no credit union failures in the first quarter of 2025. In addition, there was a reduction in the number of CAMELS 3, 4, and 5 credit unions. 


The briefing on the Voluntary Separation program describes the NCUA’s program and expects approximately 250 employees to depart as part of this program. To date, 152 employees have been placed on paid administrative leave under the NDRP until they officially separate from the agency no later than Dec. 31, 2025. The remaining NDRP participants will start their administrative leave in the weeks and months ahead. The NCUA’s VSIP option offered a separation incentive payment of $50,000 to employees who are, or will become, regular retirement eligible and who separate from the agency by Dec. 31, 2025. 


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Federal Reserve Bank (FRB) 


First Issue 2025 of Consumer Compliance Outlook 


The FRB issued the first issue of the 2025 Consumer Compliance Outlook (CCO).  This issue includes articles on: 

  • 2024 Aggregate Supervisory Data for Institutions the Federal Reserve Supervises 

  • Top-Cited Federal Reserve System Compliance Violations in 2024: HMDA 

  • Community Reinvestment Act Data Collection and Reporting Violations 

  • Record Retention Reference Guide for Federal Consumer Protection Laws and Regulations 

  • Regulatory Calendar 


FedWire Funds Service Implementation of ISO 20022 Messaging Standard 


On July 14, 2025, FedWire Funds will adopt the ISO 20022 message format for Fedwire Funds Services and sunset the existing proprietary Fedwire Application Interface Manual (FAIM) and replace all FAIM messages with ISO 20022 messages. The ISO 20022 implementation date also applies to the Financial Institution Reconcilement Data (FIRD) Files, Statement of Account Spreadsheet Files (SASF), and the Transaction End-of-Minute (EOM) Detail Reports. 


The financial services industry’s need for a common “language” is what led the International Organization for Standardization to launch its ISO 20022 messaging standard in 2004. Within the industry, the ISO 20022 messaging standard is used for business areas such as: 

  • Payments 

  • Securities 

  • Trade services 

  • Cards 

  • Foreign exchange 


Financial services organizations in more than 70 countries currently use the ISO 20022 standard. 


ISO 20022 messages are vital to instant payments and play an important role in the overall modernization of payment processes. Specifically, they provide a structured and data-rich common language that is readily exchanged among corporates and banking systems. This capability is foundational for innovations like moving from end-of-day batch file processing to real-time payment processing. Additionally, ISO 20022 messages provide the opportunity for enhanced analytics, which can lead to offering valuable new levels of payment services to financial institutions’ customers. 


Broad industry adoption of the ISO 20022 messaging standard and the benefits of its highly structured data made it the logical choice for the FedNow Service, the Federal Reserve’s instant payments infrastructure. And because ISO designed the standard to meet the needs of future innovation, it can support the FedNow Service as it evolves and adds capabilities. 

  

What Credit Unions Should Do Now: 

  

  1. Credit Unions using a service provider: If your servicer provider has not already shared their plans for the ISO 20022 migration, reach out to them and ensure there are plans in place for the migration. 

  2. Credit Unions with direct Fedwire Funds service connection: FedNow should have informed the credit union about the upcoming change. Inventory the systems that support credit union wire operations, reach out to your internal software developers or vendors. 

  3. Become familiar with the ISO 20022 standards: The Federal Reserve is using the MyStandards platform to provide access to the FedNow ISO 20022 message specifications and accompanying implementation guide. These can be accessed on the Federal Reserve Financial Services portal (Off-site) under the FedNow Service. Users will need a MyStandards account, which can be created on the SWIFT website (Off-site). View the step-by-step guide for tips on accessing the specifications. 

  4. Review information in the Fedwire Funds Service ISO 20022 Implementation Center: Credit unions can access various resources shared by FedNow on the Implementation Center website. 


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Semi-Annual Oregon Escrow Rate Adjustment 


The rate financial institutions in Oregon must pay on real estate loan escrow accounts is established in ORS 86.245. The rate on these accounts must be adjusted on Jan. 1 and July 1 of each year.  
  
For each change period, January and July, the rate is based on the most recent auction date information for the 91-Day Treasury Bill (AKA 13-week Treasury Bill) prior to Nov. 15 and May 15, respectively. The rate is calculated by subtracting 100 basis points from the discount rate that corresponds to the applicable auction date.  
  
Interest shall be computed on the average monthly balance in the account and shall be paid not less than quarterly to the borrower by crediting to the escrow account the amount of the interest due.  
  
The discount rate for the 91-Day/13-week Treasury Bill as of auction date May 14, 2025, was 4.29%*. Because the discount rate is greater than 1%, subtracting 100 basis points will result in a rate of 3.29%.  Credit unions with escrow accounts for real estate in Oregon will be required to pay interest of 3.29% on escrow accounts for the period July 1 – Dec. 31, 2025.  
  
*Source: Treasury Direct  



League InfoSight Highlight

 

CFPB Withdraws Three Proposed Rules; Search for a Permanent Director Continues

 

On May 15, 2025, the Consumer Financial Protection Bureau (CFPB) published notice in the Federal Register that it is withdrawing three proposals introduced under the previous administration.


First, the CFPB is withdrawing a proposed interpretive rule regarding applicability of the Electronic Fund Transfers Act to emerging payment mechanisms. Under the January 2025 proposal, a stablecoin, bitcoin, or other cryptocurrency transaction conducted in connection with a consumer asset account would have been considered an electronic fund transfer subject to Regulation E’s requirements.


Next, the CFPB is withdrawing a proposed rule that would have banned unfair provisions in credit contracts and specifically prohibited certain terms and conditions. Under the January 2025 proposal, a credit contract could not contain provisions such as a confession of judgment or waiver of exemption. In addition, a covered financial institution would not be able to enforce any term or condition that permitted it to unilaterally amend a contract or restrain expression.


Finally, the CFPB is withdrawing its proposed rule concerning harmful data broker practices. The proposal, issued in December 2024, would have treated data brokers as consumer reporting agencies, required a permissible purpose to obtain credit header data (e.g., name, address, date of birth, and social security number of a consumer) from a consumer reporting agency, and emphasized that marketing is not a permissible purpose to obtain a credit report under the FCRA.


On May 9, 2025, the White House announced that President Trump is nominating Jonathan McKernan as Undersecretary of Treasury for Domestic Policy. It was later confirmed that as a result, Mr. McKernan’s previous nomination to head the CFBP is being withdrawn. Russell Vought, the Director of the White House Office of Management and Budget, is currently serving as acting director of the Bureau. He may continue to do so for an additional 210 days under the Federal Vacancies Reform Act. The White House has yet to announce a new nominee for CFPB director.


ARTICLES OF INTEREST


The Sweet Escape: CFPB Won’t Prioritize Enforcement of Section 1071 


NCUA Charters African Diaspora Federal Credit Union 


The Latest on CFPB’s Open Banking Rule 


SCAM UPDATES


Notice in the Mail About Your Property? Here’s What to Know 


Let’s Talk About Scams This Older Americans Month 


Spotting Student Loan Scams 


Threat Actors Deploy LummaC2 Malware to Exfiltrate Sensitive Data from Organizations 



COMPLIANCE CALENDAR

May 28, 2025: NCUA Webinar – Planning for Retirement with Credit Unions 


June 15, 2025: CFPB – Prohibition on Creditors and CRAs Concerning Medical Information (Regulation V) 


June 23, 2025: NCUA comments due on Simplification of Share Insurance and Succession Planning 


June 23, 2025: NCUA comments due on Changes to the Call Report  


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


July 14, 2025: Effective Date – FTC Negative Option Rule 


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) 


Dec. 30, 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 


TOOLS & RESOURCES

Effective Dates
Bulletins & Alerts
Webinar Calendar
AffirmX and GoWest Partnership

Q&A OF THE WEEK

Are funds in an IRA subject to a garnishment? 


Generally speaking, no. IRA funds are exempt from garnishments. However, if the member removes funds from the IRA and places them in a regular share savings or checking, those funds can be garnished. 

For your individualized login, select your state below. 

Arizona
Colorado
Idaho
Oregon
Washington
Wyoming

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, 

David Curtis

CUCE

Director, Compliance Services
P: 206.340.4785

Tiarra Sanders-Hausa

NCCO

Manager, Compliance Services

P: 206.618.9302

Copyright © 2025 GoWest Credit Union Association. All Rights Reserved.

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

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