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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)


NCUA Invites Stakeholder Feedback on Operations and Initiatives 


The NCUA has invited stakeholders to provide suggestions and feedback on the agency’s operations and initiatives to aid in developing the NCUA’s 2026–2030 Strategic Plan, which guides the agency’s operational and budgetary priorities. 


Stakeholders can submit their feedback and suggestions by emailing AskNCUA@ncua.gov. The feedback received will inform the development of the agency’s 2026–2030 Strategic Plan and its 2026–2027 budget. 


As part of its compliance with Executive Order 14210, Implementing the President’s “Department of Government Efficiency” Workforce Optimization Initiative, the NCUA implemented its Voluntary Separation Program(Opens new window) to reduce the size of its workforce. The NCUA is also restructuring its operations to improve its effectiveness and efficiency while protecting the system of cooperative credit and its member-owners. The agency anticipates the 2026-2030 Strategic Plan will further reinforce NCUA’s changes under the leadership of Chairman Hauptman consistent with the goals of Executive Order 14210. 



League InfoSight Highlight

 

CFPB Takes Steps to Limit State Attorney General and Regulator Authority 


On May 15, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule attempting to limit the authority of state attorneys general and financial institution regulators when it comes to enforcing federal consumer financial protection law.  

  

Section 1042 of the Dodd-Frank Wall Street Reform and Consumer Protection Act allows a state attorney general or financial institution regulator to “bring a civil action to enforce provisions of this title or regulations issued under this title.” In a now withdrawn interpretive rule from 2022, the previous CFPB administration had interpreted this statutory provision to allow a state attorney general or financial institution regulator enforcement authority over any federal consumer financial protection law.  

  

Under its new interpretive rule, the CFPB indicates that state enforcement activity is limited to those rules specifically promulgated under the Dodd-Frank Act. This would limit state attorney general and regulator authority to things such as the prohibition against unfair, deceptive, and abusive acts and practices. It would not permit enforcement at a state level under any other federal consumer financial protection law. For example, a state attorney general or regulator could not bring an action to enforce a provision of the Truth in Lending Act, the Fair Credit Reporting Act, or the Equal Credit Opportunity Act (to name a few).  

  

In recent months, as the new CFPB has sought to unwind most of the work done under the previous administration, many in the industry envisioned state attorneys general and regulators stepping up to fill the void in consumer financial protection. This new interpretive rule appears to be the agency’s attempt to proactively cut that notion off at the pass. While it remains to be seen what consumer financial protection will look like in the future, it’s safe to say we can expect a lot more litigation on this subject in the years to come. 


Section 1033 Personal Financial Data Rights Rule Likely to be Struck Down by Month’s End 


In late 2024, the Consumer Financial Protection Bureau finalized its personal financial data rights rule as required by Section 1033 of the Dodd-Frank Act. The rule requires financial institutions and other data providers to make covered data regarding financial products and services available to consumers and authorized third parties in electronic form. 


Almost immediately, the CFPB was sued in federal district court in Kentucky, alleging several deficiencies with the rulemaking. On May 23, the CFPB’s general counsel indicated that the agency plans to file a motion for summary judgment by May 30 asking the court to cancel the rule. In a status report filed with the court, the CFPB stated, “after reviewing the rule and considering the issues that this case presents, Bureau leadership has determined that the rule is unlawful and should be set aside.” 


Notwithstanding this development, financial institutions must keep in mind that Section 1033 of the Dodd-Frank Act statutorily mandates that the CFPB prescribe rules requiring covered persons to make certain information about financial products and services available to consumers in electronic form. Absent an act of Congress striking this requirement from the Dodd-Frank Act, the CFPB will need to start anew with its open banking initiative. Stay tuned for more information! 



ARTICLES OF INTEREST


FinCEN Exceptive Relief to Financial Institutions Regarding Commercial Bank of Syria 


H.R. 1 - One Big Beautiful Bill Act and Compliance Implications 


U.S. DOL Rescinds 2022 Guidance on Cryptocurrency in 401(K) Plans 


Supreme Court Ruling Temporarily Permits Removal of Independent Board Members 


SCAM UPDATES


No, FTC ‘agents’ With Badge Numbers Aren’t Calling You 


Can You Spot an Investment Scam on Social Media? 


Treasury Takes Action Against Major Cyber Scam Facilitator 



COMPLIANCE CALENDAR

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

If an account is set up as a FBO are the funds protected from garnishment? 


It depends on how the account is set up and who the writ of garnishment is on. 


For example: John Doe FBO Jane Doe. 


This account would be similar to a POD or In Trust For account.  These are all versions of Totten Trusts. The account is owned by John Doe and will pass to Jane Doe upon his death. The account would be subject to a garnishment order naming John Doe. It would not be subject to one naming Jane Doe. John has the ownership rights on the account, but Jane does not have ownership rights. 

For your individualized login, select your state below. 

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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.

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

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