NWCUA Regulatory Advocacy Update: Association Meets with NCUA Northwest Leadership
April 19, 2012
April 19, 2012
Northwest Credit Union Association (NWCUA) staff recently met with the Northwest’s three National Credit Union Administration (NCUA) Supervisory Examiners (SEs) and Region V Associate Regional Director of Programs Mike Dyer. SEs Jason Winship, who mostly works in Washington, and Hilary Tormala, who handles Oregon, were joined this year by veteran Leslie Thomson. Thomson will be working primarily in Portland, Vancouver, Seattle and Alaska and comes to the Northwest after many years as an SE in Hawaii.
“These meetings are a great opportunity to build relationships and discuss emerging issues,” said NWCUA Director of Regulatory Advocacy Jaycee Winn. “We appreciate the NCUA taking the time to meet with us and listen to the concerns of credit unions.”
One topic discussed was the increase in the use of documents of resolution (DORs) among credit unions nationwide. While new to many credit unions, the NCUA uses these as a tool to resolve issues; they help to track ongoing items for follow-up and are not meant to be a “report card.” Credit union boards and management are encouraged to work with examiners if DORs are issued to help ensure that the content is relevant and accurate and that it is helpful to the credit union. They are not set in stone, and credit unions should take the time to discuss them with their examiners.
When discussing marketing, the NCUA team also had some good advice: take advantage of local colleges. For those credit unions in college towns, they suggested working with local college students studying marketing to help provide insight and bandwidth for marketing efforts. Many students need real-life experience in their field, and working with a local business is a great way to gain that experience and provide fresh insight.
Again emphasized was the need for open communication and discussion all year long, not just during exam time. Both sides recognized the tough economic climate and stress credit unions are under, which can make for a tough exam and an unpleasant experience for all sides. When possible, examiners will be attending chapter dinners and working to spend more time outside of exams with credit unions.
“We appreciate the openness of the NCUA and value these dialogues,” Winn said. “If you have any questions for the NCUA that you would like us to bring up at future meetings or have any issues you would like help addressing, please let us know.”
Oregon Attorney General Holds Mortgage Foreclosure Working Group
One of the major issues addressed during the Oregon Legislature’s short session this year was foreclosure legislation. Although the final bill did not take into account several of the Association’s desired changes, it does exempt trustees or beneficiaries who have commenced fewer than 250 foreclosures during last 12-month period from most of the provisions in the bill.
The Attorney General’s office has begun a working group that is tasked with developing a foreclosure mediation program. Because of the short 91-day operative date for the legislation, the process is moving swiftly along, and the Association is taking part.
If any credit unions are interested in offering feedback on the foreclosure mediation program, please contact Jaycee Winn to coordinate these efforts.
Learn more about the working group here.
CFPB Issues First Annual Report on Consumer Complaints
The Consumer Financial Protection Bureau (CFPB) issued its first annual report to Congress on the complaints received from July 21, 2011, through the end of the year. The CFPB began taking credit card complaints on July 21 and mortgage complaints on Dec. 1, and during that time it received 13,210 complaints, including 9,307 on credit cards and 2,326 on mortgages.
The majority of complaints (44 percent) were submitted via the CFPB website, and nearly 35 percent were referred to the CFPB from other regulators. More than half of the mortgage complaints involved a consumer being unable to pay or issues with servicing.
The CFPB forwarded 75 percent of the complaints to companies for review, with 88 percent of those receiving responses. Companies are now given 15 calendar days to respond to requests rather than 10 to encourage increased participation. The 25 percent not forwarded were generally found to be incomplete, not matters handled by the CFPB, or pending at the time of the report.
Interestingly, 55 percent of the cases were reported being closed with “relief” and 30 percent without —meaning the resolution “may have addressed some or all of the consumer’s complaint involving non-monetary requests.” Consumers generally did not dispute the responses, with only 13 percent contesting at the end of the reporting period. The CFPB will be most likely to investigate instances where the consumer is unhappy with the response or a company does not respond in a timely manner.
Looking at these numbers, the question still begs to be answered: is the role of the CFPB to forward consumer complaints to companies? The value of having a Federal agency log and forward such complaints seems lost when most companies would handle these complaints in the same manner if addressed directly through their own channels.
“Certainly, consumers should have a place to turn when they need help, but run-of-the-mill complaints could likely be managed in a more efficient manner that would cost the taxpayer significantly less,” Winn said. “It will be interesting to see, as these reports continue, what impact this process is having on consumers and on companies, if this is a manageable process for the CFPB when it adds additional services, such as student loans and consumer loans.”
Read the full 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.