Servicing Rules “Mortgage Servicing Transfer Notice” was ...

October, 2017

Dear CU PolicyPro Client,

Happy Fall!

CU PolicyPro Updates

If you haven't seen them already, please make sure you take a look at our most recent updates pushed out to users at the beginning of the month. As mentioned in our newsletter last month, the Home Mortgage Disclosure Act (HMDA) policy was updated to comply with the changes that become effective on January 1, 2018. There were also updates related to NACHA rule changes, record retention and member expulsion/abuse policies. Visit our support site for more information.

Policy 7361 ? Small Servicer Mortgage Servicing Rules - CORRECTION

We also wanted to draw attention to a correction we needed to make in Policy 7361 ? Small Servicer Mortgage Servicing Rules. In our June 2017 updates to comply with the new mortgage servicing rules, Section 5 related to the "Mortgage Servicing Transfer Notice" was removed. However, this section would be applicable to Small Servicers only if they acquire ownership of a mortgage loan and subsequent servicing rights of an affiliate. Therefore, we have added this section back in to the model policy.

However, if the credit union does not purchase mortgage loans with servicing rights from affiliates, they should remove that section from the policy.

Remember, a small servicer is a servicer that services (together with any affiliates) 5,000 or fewer mortgage loans, for all of which the servicer (or an affiliate) is the creditor or assignee. Therefore, credit unions could only purchase mortgage servicing rights for loans for which their affiliate originated, otherwise they would lose their small servicer exemption.

Please let us know if you have any questions on the applicability of these requirements outlined in Regulation Z ? 1026.39.

In this edition:

Monthly OPS Notes Release: NACHA Third-Party Sender Registration Content FAQs Technical FAQ Questions?

Monthly OPS Notes Release: NACHA Third-Party Sender Registration

Third-Party Sender Registration Effective at the end of last month (September 29, 2017), NACHA opened up their registry for credit union Originating Depository Financial Institutions (ODFIs) to register all of their Third-Party Senders. Credit union ODFIs have until March 1, 2018 to enter their information in the registry. Below is the information the credit union ODFI has to record as part of the initial registration:

? The credit union's name and contact information. ? The name and principal business location of the Third-Party Sender. ? The routing number of the credit union (utilized by the originator). ? The Company identification(s) of the Third-Party Sender.

Credit union ODFIs may also be requested by NACHA to provide additional information to the registry upon request due to a risk event.

Don't have any Third-Party Senders? Your credit union still isn't off the hook. Even if credit union ODFIs do not have any Third-Party Senders, they are still required to indicate that on the registry. Additionally, credit union ODFIs should also develop procedures to address any new or changed Third-Party Senders. NACHA rules indicate that credit union ODFI's have 45 days following any change to update the registry. Credit union ODFIs can access the registry here.

Content FAQs

Question: What if our credit union isn't an ODFI, do the rules still apply?

Answer: No, the registry requirements only apply to credit union ODFIs.

Question: What if our credit union doesn't register its Third-Party Senders?

Answer: According to NACHA, this would be a Class 2 Rules Violation (Subpart 10.4.7.4). The ACH Rules Enforcement Panel may levy a fine against the Credit Union in an amount up to $100,000 per month until the problem is resolved.

Question: Our credit union is having a hard time determining who our Third-Party Senders are. Is there any guidance that can assist?

Answer: Yes, NACHA indicates that sometimes ACH roles may not always be easily identifiable, so they have created a Third-Party Sender Identification Tool for financial institutions to utilize.

Technical FAQ

Question: How can I add new users to CU PolicyPro?

Answer: Any admin user can add additional users, including other admins. To add a new user:

1. Go to the ADMINISTRATION area of CU PolicyPro.

2. Click on the "Users" button on the left navigation.

3. A list of current users will appear. Click the "New" button on the far right side of the screen.

4. The "New User" form will appear.

5. Two types of users can be created: Individual or Group Users.

6. An Individual User is a distinct User Name and Password for a specific individual. A Group User is a User Name and Password that is shared among a group who all have the same access level (i.e. Board of Directors or Employees with read-only access).

7. For either an Individual or Group User, type in the First and Last Name (or Group Name for Group Users), the User ID, Email address, and Password. (Passwords are encrypted and must be entered in twice for security reasons).

8. From the dropdown list, choose the Access Level this user will have.

9. When you're finished, click the "Save" button.

Tip: An email address must be entered in order for the user to utilize the "Forgotten Password" function from the login screen. Group users will not have an email address option.

Click here for written instructions on adding/editing users and managing access rights or watch Segment 9 of the New User Training Video series.

If you have any additional questions or need further assistance you can contact us at policysupport@ Questions?

If this information was forwarded to you, and you'd like to be on the distribution list to receive information and updates related to CU PolicyPro, or if you have any questions regarding the CU PolicyPro content, or questions on how to use the system, please contact policysupport@.

Thanks and have a great week!

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