CUNA Regulatory Advocacy Report

Federal Bank Regulators Issue EGRPRA Notice

On February 13, the federal banking regulators published their Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA) regulatory review notice for banks. While NCUA is not part of this particular regulatory review, the review includes several Federal Reserve regulations that apply to credit unions. These include Regulation CC (funds availability) and Regulation D (reserve requirements). CUNA will be issuing a Comment Call shortly. Comments are due to the Federal Reserve by May 14.

CUNA Endorses Applicants to CFPB’s Advisory Councils

On Friday, CUNA President & CEO Jim Nussle sent CFPB Director Cordray a letter endorsing 15 credit union representatives to the CFPB’s Consumer Advisory Board (CAB) and/or Credit Union Advisory Council (CUAC). The CFPB was soliciting applicants until February 28 to fill several vacancies on the CAB and CUAC.

“Credit union representation at the Bureau is a key component to ensuring the unique perspective of credit unions’ is not only heard, but also taken into consideration as a part of any and all rulemakings affecting credit unions,” Nussle stated in the letter. Speaking of the credit union applicants, Nussle further stated that, he is “confident that with their contributions, the CAB and CUAC will accurately understand the need for protections for consumers in the financial marketplace while at the same time understanding the need to avoid burdening entities such as credit unions that already work hard to ensure their members are well served.”

The CUAC advises the Bureau on the impact on credit unions of the CFPB’s existing and proposed regulations. The CUAC is permitted to have between 15 and 20 members. It currently consists of 16 members, and is chaired by Rose Bartolomucci, President & CEO of Towpath Credit Union in Fairlawn, OH.

The CAB informs the Bureau on emerging practices and trends in the consumer finance industry. The CAB must have at least 16 members. It currently has 31 members, and is chaired by Bill Bynum, CEO of Hope Federal Credit Union in Jackson, MS.

CFPB Proposes to Temporarily Suspend Submissions of Credit Card Agreements

The CFPB is proposing to amend Regulation Z to temporarily suspend card issuers’ obligations to submit credit card agreements to the CFPB for a period of one year, as the agency develops an automated submission system. During the one-year period, card issuers will still need to post agreements on their own websites.

Under the current process, card issuers submit agreements to the CFPB via email. As described in the proposal, “The Bureau believes this process may be unnecessarily cumbersome for issuers and may make issuers’ own internal tracking of previously submitted agreements difficult. In addition, the current process for Bureau staff to manually review, catalog, and upload new or revised agreements to the Bureau’s website, and to remove outdated agreements, can extend for several months after the quarterly submission deadline. The Bureau is working to develop a more streamlined and automated electronic submission system, which would allow issuers to upload agreements directly to the Bureau’s database. The Bureau intends for its new submission system to be less burdensome and easier for issuers to use. It also intends for the new system to enable faster posting of new and revised agreements on the Bureau’s website.”

While the CFPB is not seeking input on the new submission process it is developing, please share with CUNA any concerns you might have so we can make the Bureau aware of those and other potential issues with the proposal. The CFPB is seeking comments until March 13; please send CUNA any input by March 4—the proposal was issued with only a 15-day comment period.

Financial Accounting Foundation Seeks Input on Effectiveness of Private Company Council

The Financial Accounting Foundation (FAF) is conducting an overall assessment of the Private Company Council (PCC), which was established in 2012 to identify issues in GAAP related to private companies and to work with the Financial Accounting Standards Board (FASB) on ongoing private company issues. The assessment is intended to provide the FAF with a comprehensive look at the effectiveness of the PCC in meeting its mission, as well as what changes might be made to make it more effective.

The FAF has issued a request for comment to solicit stakeholder feedback on the PCC. CUNA will be reviewing the request in detail and providing comments to the FAF prior to the May 11 deadline.

Current CUNA Regulatory Calls to Action

  • CFPB Issues Amendments to 2013 Mortgage Rules under RESPA (Reg X) and TILA (Reg Z) (comments due by March 16)
  • NCUA Seeks Input on its EGRPRA Regulatory Review (comments due by March 19)
  • CFPB Proposes Prepaid Card Rule (comments due by March 23)
  • NCUA Proposes Changes to Schedule for Capital Planning & Stress Testing (comments due by March 27)
  • CFPB Issues Proposal on Rural and Underserved Areas (comments due by March 30)
  • CFPB Proposes Safe Student Account Scorecard (comments due by March 30)
  • NCUA Issues New Risk-Based Capital Proposal (RBC2) (comments due by April 27)

For other items of interest, visit CUNA’s Regulatory Advocacy page.

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