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Durbin 2.0 Part II: Who Weighed In and What They Said

Posted by Keith Ash on Oct 18, 2021 9:30:00 AM

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As discussed in a previous blog, the Federal Reserve began seeking comments on proposed changes to Reg II of the Durbin Amendment in May. At that time, the Fed said that it felt the changes would be non-substantial and would not include more compliance obligations. Currently, the Fed bars issuers from restricting the number of unaffiliated networks for debit card transactions to fewer than two, including one signature network and one PIN network. The new proposal would make issuers responsible for ensuring that all transactions with US merchants can be routed across two unaffiliated networks.

While the Fed characterized this change as a simple clarification, it is anything but, as evidenced by the over 2,600 comments received. It is clear this issue is complex, substantial, and would increase compliance obligations.

We have sorted through the comments posted on the Fed's website and various government sites to summarize the key points for both sides of this argument.

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Topics: Payments, Credit Union Vendor Management, Durbin Amendment, Regulations

Credit Unions and Crypto: Setting the Ground Rules

Posted by Larry Pruss on Oct 11, 2021 9:30:00 AM

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In late July, the National Credit Union Administration (NCUA) issued a request for comment on the current uses of digital assets and their potential impact on the financial system. The NCUA plans to use this input to help shape its role in safeguarding consumers and the system as these emerging technologies evolve.

The request largely mirrors previous outreach by bank regulators, although the NCUA expanded its scope to include the rapidly growing field of decentralized finance (DeFi). Unfortunately, the credit union response has been muted, so the NCUA extended its deadline for comments to October 27. SRM encourages credit unions to make their voices heard on this strategically important issue.

SRM responded to the NCUA, which you can read here. Our NCUA letter serves as a solid primer on the cryptocurrency topic and includes several examples of existing banking initiatives, the highlights of which we’ll summarize below.

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Topics: Cryptocurrency, DeFi, Decentralized Finance, Digital Asset Regulation, Cryptocurrency for Banks and Credit Unions

Budgeting for 2022 | 5 Key Considerations for Your Vendor Contracts

Posted by Ben Mrva on Oct 5, 2021 11:00:00 AM

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Budgeting and planning season is usually a routine time for evaluating your business priorities and associated costs. However, while some banks and credit unions have already set their 2022 budgets, others are still calculating forecasts or waiting for more data.

Too often, management teams and boards plug vendor costs into their annual budgets and forecasts without questioning whether those contracts can be improved. This is undoubtedly a more complex task than ever as we face the coming winter months and the uncertainties surrounding the lingering impact of COVID-19.

There is, however, one area that is a sure opportunity for cost savings in your budgeting cycle – vendor contracts.

Banks and credit unions tend to plug vendor costs into their budgets and forecasts without questioning whether those contracts can be improved. This is often a mistake.

The truth is, no matter what the economic conditions, it is possible to reduce vendor costs without switching vendors or impacting service levels.

Here are 5 questions to ask when it comes to vendor contracts during this critical budget season:

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Topics: Vendor Contract Negotiation, Bank Vendor Management, Credit Union Vendor Management, Budgets

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