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Compliance Q&A: Open-End Loans

December 03, 2010

Q For open-end loans without a grace period, what’s the minimum amount of time credit unions must provide between the mailing (or delivery) of the periodic statement and the payment due date?

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Recent Discussion

In remembering Warren, the first thing I think of was his smile. He was a gentle, caring man who always thought of others first. I was honored to be a part of the MiOpportinidad project with Affinity Credit Union, Warren and Miriam. His hard work and dedication to that project was inspirational. Warren so deserves this award.

The author really understands the credit union philosophy and I really enjoyed the analogy of his bathroom remodel. The only thing missing was pictures of the finished bathroom! :)

Thank you Phillip for showing the differences between a Big Bank that is only looking to sell you products and a Credit Union that actually looks out for its members needs. Great article!

I love and give a standing ovation to Ron Kase and to other caring people just as much as those who passed away on 2012 like Warren Morrow at Des Moines Iowa. He worked hard for those who are under-served an under-represented, but wasn't mentioned in your magazine. It may be beneficial for the entire world to know about his accomplishments no for his benefit, obviously, but to increase the number of positive and caring people and to add members the CU. Just ask Coopera Consulting at Des Moines Iowa about Warren Morrow's legacy.

That’s right Lisa. The servicing rule would not require a credit union to create its own policies and procedures if all aspects of the servicing are delegated to a sub-servicer. However, remember that the credit union will have to conduct due diligence on the sub-servicer to make sure it is following the minimum requirements for policies and procedures. Unfortunately, even those credit unions that use a third party servicer will need to have a working knowledge of the CFPB’s servicing rule.

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