CUNA Regulatory Update
November 30, 2015
November 23, 2015
Here is what you need to know about credit union advocacy this week:
- NCUA issued a comprehensive field of membership proposal, including many recommendations that CUNA made earlier this year.
- NCUA Chairman Matz signaled the agency’s willingness to move toward an 18 month examination cycle for well-performing credit unions as regulatory relief and technological advancements are implemented.
- The House passed CUNA-supported legislation to treat mortgages held in portfolio as Qualified Mortgages.
- CUNA and Leagues dealt the retailer lobby a setback by convincing dozens of state attorneys general from signing a letter endorsing Chip and PIN technology.
- The CFPB has issued a revised rulemaking agenda, pushing back new regulations on payday lending and overdraft protection.
Congress is in recess for the Thanksgiving holiday. When the chambers return next week, the race to the end of the first session of the 114th Congress will be intense, and several credit union priorities are teed up for action.
Our legislative strategy this year has been to get as many provisions as possible through the process in the House and Senate committees in order to ripen them for consideration on end of the year “must-pass” vehicles. We’ve had to take this path because of the challenges in getting legislation – any legislation – through the Senate. As we approach the final days of the legislative session, there are two such vehicles that hold promise for CUNA-supported provisions.
The House-passed highway trust fund bill contains two provisions that we strongly support: modernizing annual privacy notification requirements and permitting privately insured credit unions to join the Federal Home Loan Bank (FHLB) system. This legislation is being reconciled with the Senate-passed bill in a conference committee, which is expected to present a report to both chambers next week, in advance of a December 4th deadline.
The Financial Services and General Government appropriations bills both contain CUNA-supported provisions as well. The Senate bill has nearly a dozen regulatory relief provisions that would benefit credit unions, including provisions that would deem mortgages held in portfolio as Qualified Mortgages, provide for greater NCUA budget transparency and address concerns with the Federal Housing Finance Agency’s proposal on FHLB membership requirements. The House version includes, among other provisions, measures related to the CFPB’s structure. These bills need to be reconciled and combined with other appropriations measures before funding for the government runs out on December 11. While we are very certain that several provisions will not make the final cut, we continue to press for inclusion of as many as possible.
Pending Regulatory Comment Calls
CUNA intends to comment on the following pending regulatory proposals. For our comment letter to have the greatest impact, we need to hear from you. Please consider whether and how these proposals would affect your credit union. If you have feedback or questions regarding any proposal, please contact the CUNA staff listed with each proposal.
We encourage Leagues and credit unions to use PowerComment to file comment letters with regulators. For more information regarding these proposals, please follow the links below:
|Investments & Deposit Activities – Banks Notes||November 23, 2015||NCUA||Lance Noggle|
|OMB re: Joint Standards for Assessing Diversity Policies and Practices||December 7, 2015||Joint||Leah Dempsey|
|OMB Request re: HMDA Data Collection||January 11, 2016||CFPB||Andy Price|
|Field of Membership||TBD||NCUA||Lance Noggle|
A note regarding Field of Membership: we view this proposal as very positive for credit unions and we will be strongly encouraging credit unions to comment on the proposal, and to ask their employees and volunteers to engage as well. Please look for additional information in the coming days on the Removing Barriers Blog and on our Field of Membership page.
Last Week on the Removing Barriers Blog
The CFPB released its fall rulemaking agenda, providing some insight into what issues it will be focusing on in the next several months.
The NCUA Board proposed comprehensive changes to its field of membership regulations. See Also: Field of Membership Proposal Expected to be Released Thursday This week, we expect NCUA to propose a new field of membership regulation that incorporates several of the recommendations we proposed earlier this year.
Here is our summary of last Thursday’s NCUA Board meeting.
The House approved a bill that would allow credit unions and other lenders to treat mortgages held in portfolio as qualified mortgages (QM).
See also: Letter to House Urging Support of Portfolio Lending Bill Last week, we sent a letter to U.S. House lawmakers, encouraging them to vote yes this week on a measure that would remove a significant barrier for credit unions.
The Financial Accounting Foundation (FAF) adopted several changes to the operating procedures of the Private Company Council (PCC), which is the primary advisory body to FASB, on accounting issues affecting credit unions.
A recent effort by the retail industry to hype the power of chip-and-PIN technology to address data security problems seems to have fallen well short of its goal.
Last week, we sent a letter urging Congress to address the recent TCPA ruling and Order from the FCC, which has created some significant problems for credit unions.
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