Loan Fees and New Periodic Member Statements

As CBS fielded the New Periodic Member Statements for Reg Z, some member statements have incorrectly reported fee information because some transaction codes were marked as loan fees that are not loan fees. For example, loan payments, loan advances, loan transfers, distribution transfers, etc., are not loan fees. Having these marked as fees will cause statements to incorrectly report fees.

Some loan-related fee transaction codes were automatically marked as loan fees in Transaction Code Maintenance by CBS, but CBS cannot create a “template” of all fees that require disclosure, so we must rely on individual compliance officers within credit unions to determine which fees must be disclosed.

What should you do?

CBS recommends that you recheck the way you have marked the transaction codes for loan fees, simply selecting (checking) everything that looks like it affects loans may disclose information incorrectly on member statements. Make corrections as needed before processing year-end.

What do I do if I find something incorrectly selected (checked)?

Clear (uncheck) the Loan Fee check in the Control-Master Events/Fee for those fees that are not considered disclosable and clear the Transaction Code Maintenance Reg Z Disclosable Loan Fee? check box in the Transaction Code Maintenance screen for that transaction code. You can also track transaction codes to G/L Accounts by going to G/L > Reports >Interface Debits/Credits and requesting a report for all of the transaction codes by accepting the Default setting.

CBS also strongly recommends that you contact the appropriate regulatory agency with any compliance questions.

Please address any questions concerning this posting to the CBS Issue Tracking System.