NWCUA Regulatory Advocacy Update
November 2, 2011
November 3, 2011
NCUA Has Much to Ponder on CUSO Proposal
The National Credit Union Administration (NCUA) has reported receiving nearly 300 letters in response to their proposal to require CUSOs to report directly to the NCUA. Acknowledging that this was a hot issue, the NCUA has stated that they will likely not take action before next year, citing the time it takes to review all comments received. The Northwest Credit Union Association (NWCUA) weighed in on the proposal, requesting that it be withdrawn and calling it a regulatory overreaction due to a few bad actors within the industry.
“We are pleased to see that the NCUA is taking industry input seriously and looking to make changes based on those comments,” NWCUA Director of Regulatory Advocacy Jaycee Winn said. “We look forward to working together as the NCUA continues to promulgate regulations.”
CFPB Asks for Input on Student Loan ‘Know Before You Owe’ Forms
In an effort similar to its “Know Before You Owe” mortgage forms, the Consumer Financial Protection Bureau (CFPB) has partnered with the Department of Education in developing a simple model financial aid form that schools can use to clearly communicate financial aid offers and plans to students and parents.
Over the past few weeks, the CFPB has been holding town halls throughout the country. Last week, several of the events were televised, and second only to mortgage and foreclosure concerns were concerns about student lending.
Those interested in weighing in on this first draft of the student lending form can do so by visiting the CFPB student lending site.
Opportunities for Involvement in Regulatory Advocacy: Have Your Voice Heard!
The NWCUA is seeking member comment on several proposed regulations. Most recently added is the Department of Treasury’s solicitation for recommendations on financial education and access programs. A provision in Dodd-Frank gave the Treasury’s Office of Financial Education and Financial Access (OFEFA) the authority to put together programs that will expand access to mainstream financial institutions to those who may be unbanked or under-banked.
This solicitation is a great opportunity for credit unions to weigh in on programs that could help expand education on the credit union industry and provide resources for underserved populations.
To read more about this proposal and other pending proposals, visit the NWCUA’s Regulatory Advocacy Comment Call page.
NCUA Holds Brief Board Meeting
The NCUA held a brief board meeting last week approving a final rule and providing updates on the National Credit Union Share Insurance Fund (NCUSIF) and Temporary Corporate Credit Union Stabilization Fund.
In an effort to streamline the application process and increase the number of low-income credit unions applying for below-market-rate loans under the Community Development Revolving Loan Fund, the board approved a new final rule. The final rule is aimed at lessening regulatory burden, eliminating outdated procedures and increasing transparency throughout the process. Examples of changes include:
- Application simplification
- Single loan maximum increased to over $300,000 in certain circumstances
- No mandatory matching requirement
- Potential for lower interest rate
- Clearer regulation
- New option to fund urgent needs
- Flexible repayment of loan principal
The rule will become final 30 days after publication in the final register.
In addition, the board reviewed the status of the NCUSIF and reported that its equity ratio stood at 1.31 percent as of Sept. 30, 2011. The ending reserve balance was almost $1 billion, including $22.5 million in reserve for specific natural-person credit unions and $976 million in non-specific reserves. Losses to the fund were $217,000 in September.
The stabilization fund recorded assessment revenue of $1.96 billion. Total liabilities stood at approximately $8 billion, with $3.5 billion in outstanding U.S. Treasury funds.
As of September, 384 credit unions were rated CAMEL 4 or 5, and 1,777 were CAMEL 3’s. Approximately 18 percent of all credit unions fall into these categories.
Read the full NCUA board report here.
The NWCUA Regulatory Advocacy team works with state and federal regulators to help reduce the regulatory burden on credit unions and protect the credit union movement. The Association encourages members to participate in the regulatory process. If you have any questions on these or any regulatory issues, please contact Director of Regulatory Advocacy Jaycee Winn at firstname.lastname@example.org, or at 800.995.9064 x209.