CUNA Advocacy Update

Reporting from CUNA

Just nine days remain until the end of the fiscal year, and the prospect of another government shutdown looms large in Washington.

This week, the House and the Senate are in session, joining legislatures in Massachusetts, Michigan and Wisconsin, which are in regular session.  Illinois remains in extended session and New Jersey is scheduled to return from recess. In addition, nine states are prefiling for the 2016 session.

Here is what you need to know about credit unions and advocacy this week:

  • Observance of Yom Kippur coupled with the appearance of Pope Francis will abbreviate the House and Senate schedule this week.
  • NCUA removes barrier to field of membership expansion.
  • California and Nevada House Members write NCUA regarding RBC2.

In Congress

The House will consider H.R. 348, the “Responsibly and Professionally Invigorating Development (RAPID) Act”.  The Senate will resume consideration of the motion to proceed to the “Pain-Capable Unborn Child Protection Act” (H.R. 36).

The abbreviated week means that there is only one hearing of note to credit unions:  On Wednesday, the Senate Homeland Security and Governmental Affairs Committee Regulatory Affairs and Federal Management Subcommittee will hold a hearing on “Examining the Use of Agency Regulatory Guidance.”

Pending Regulations

CUNA intends to comment on the following pending regulatory proposals and encourages credit unions to consider submitting comments as well.  We encourage the use of PowerComment to file comment letters with regulators. For more information regarding these proposals, please follow the links below:

Issue Comment Period Deadline Agency CUNA Staff Contact
**Closing Today** FFIEC Cybersecurity Assessment Tool September 21, 2015 Office of the Comptroller of the Currency Luke Martone
**Closing this This Week** EGRPRA Review September 22, 2015 NCUA Andy Price
Expanding Access to Credit Through Online Marketplace Lending September 30, 2015 Treasury Luke Martone
Third-Party Sender Registration October 9, 2015 NACHA Leah Dempsey
ALM/SAR Filing Requirements for Financial Advisors November 2, 2015 FinCEN Luke Martone
Request to Develop Survey on POS/ATM Overdraft Disclosures November 3, 2015 CFPB Luke Martone

Barrier Removed:

NCUA Removes a Barrier to Field of Membership Expansion

CUNA’s effort to improve NCUA’s Field of Membership (FOM) regulation bore its first fruit last week, when NCUA Chairman Matz announced the removal of a FOM approval process barrier.

During NCUA staff’s presentation of Charlotte Metro Federal Credit Union’s community charter application, Chairman Matz said that NCUA will no longer require Board approval for FOM expansion requests, which should shorten the approval process by up to 2 months.  NCUA staff will now be empowered to make these decisions without waiting for the Board.  We hope that this is the first in many regulatory barriers that NCUA will remove from its FOM processes.

CUNA/League System Advocacy in Action:

California and Nevada House Members Write NCUA Regarding RBC2  

At the urging of the California and Nevada Credit Union Leagues, on Friday, a dozen U.S. House Members wrote the National Credit Union Administration expressing concern over the agency’s RBC2 proposal.  

Here is what the Leagues had to say on their blog:  

This morning on Capitol Hill, Rep. Juan Vargas (D-Chula Vista) led 11 of his colleagues from California and Nevada in sending a letter to the NCUA raising on-going concerns with the agency’s risk-based capital (2) proposal. The Vargas letter was initiated by a request from the CA & NV Leagues and was advocated as a top priority during the Leagues’ Hike the Hill to Washington D.C. last week. The Leagues applauds the bi-partisan leadership of Congressman Vargas and thanks the 11 co-signers from our two state delegation: Representatives: Mark Amodei (R-Reno), Brad Sherman (D-Sherman Oaks), John Garamendi (D-Fairfield), Joe Heck (R-Henderson), Ami Bera (D-Sacramento), Julia Brownley (D-Ventura), Doug LaMalfa (R-Chico), Eric Swalwell (D-Livermore), Lucile Roybal-Allard (D-Downey), Pete Aguilar (D-Redlands), and Norma Torres (D-Ontario). Congressman Vargas is California’s newest member of the House Committee on Financial Services.   

Click here to view the letter.  

Kudos to the Leagues for organizing the letter and pushing the issue on their recent Hike the Hill.  It’s an important example of the importance of the CUNA/League system in advocating for credit unions.  

Last Week on the Removing Barriers Blog

US House Holds Two Hearings on Dodd-Frank Regulatory Burden  

Two hearings in the US House of Representatives last week focused on the growing regulatory burden faced by financial institutions since the Dodd-Frank Act was passed into law.

NCUA Holds September Board Meeting  

At last week’s NCUA board meeting, the agency issued a final IRPS and Final Rule on Regulatory Flexibility Act Asset Threshold, Aggregate Lending Limit for Corporate Credit Unions, and a Final Rule Implementing Statutory Inflation of Civil Money Penalties.

FFIEC Cybersecurity Assessment Tool Should Remain Voluntary  

CUNA sent a letter to the Office of the Comptroller of the Currency, which is collecting comments on behalf of the Federal Financial Institutions Examination Council (FFIEC).  The FFIEC is currently soliciting input on the reporting burden associated with its recently released Cybersecurity Assessment Tool.

CUNA Representatives Meet with CFPB to Discuss Pending Regulations  

Last week, CUNA met with representatives of the CFPB to discuss pending and anticipated rulemakings, continuing our regular advocacy on behalf of credit unions.

CUNA Representatives Meet with CFPB to Discuss Pending Regulations  

Last Friday, CUNA and other trade associations wrote a letter urging two committees in Congress to hold hearings on the impact of the FCC’s recent TCPA ruling.

CUNA Urges Congress to Hold Hearing on Recent TCPA Ruling  

Last Friday, CUNA and other trade associations wrote a letter urging two committees in Congress to hold hearings on the impact of the FCC’s recent TCPA ruling.   As always, if you have any questions regarding these or any advocacy issues, please do not hesitate to contact me.  


Ryan Donovan, CUDE
Chief Advocacy Officer
Credit Union National Association

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