CUNA Advocacy Update

The House is out this week, but the Senate is in session. Thirty seven state legislatures will be in session by the end of this week. The deadline for comments on the Field of Membership proposal is quickly approaching, and we have released a new comment letter guide to help you develop your comment letter. Payday lending takes center stage in a new op-ed in The Hill. Mark McWatters nominated for Ex-Im Bank Board. Royce and Pocan form the Congressional Cooperative Business Caucus. All of this and more in this week’s CUNA Advocacy Update…

In Congress:

The House is in recess. The Senate is expected to consider H.R. 4038, the American SAFE Act of 2015, also known as the American Security Against Foreign Enemies Act of 2015.

In Committee:

Nothing relevant to credit unions.

Your Comments and Feedback Help Remove Barrieres:

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, and contact the CUNA staff listed with each proposal with your feedback.

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:

Regulatory Impact Assessment & Initial Regulatory Flexibility Analysis regarding FinCEN’s Customer Due Diligence Proposal January 25, 2016 FinCEN Luke Martone
Field of Membership February 8, 2016 NCUA Lance Noggle
Views on the Framework for Improving Critical Infrastructure Cybersecurity February 9, 2016 NIST Lance Noggle
Rules & Regulations Under the Trade Regulation Rule Concerning Preservation of Consumers’ Claims & Defenses (The Holder Rule) February 12, 2016 FTC Leah Dempsey
Enterprise Duty to Serve Underserved Markets March 17, 2016 FHFA Andy Price
HMDA Resubmission Guidelines March 14, 2016 CFPB Andy Price
EGRPRA Review March 22, 2016 NCUA Andy Price

Field of Membership Comments Needed:

The February 8 deadline for comments on NCUA’s Field of Membership Proposal is quickly approaching. So far, the response has been very good: more than 1,200 comment letters have been filed, mostly by individuals in support of the proposal. But we need to keep this up. This week, we released a new comment letter guide to help credit unions develop substantive comment letters. These letters are crucial to moving NCUA’s positive changes across the finish line. If you have points or perspective you hope we will include in our comment letter, please share them with Elizabeth Eurgubian or me soon.

McWatters Nominated for Ex-Im Bank Board:

Last week, the president announced he intends to nominate NCUA Board Member J. Mark McWatters to the board of the Export-Import Bank. Read more about our analysis of this development here.

Barrier Removed – FHFA Removes CUNA-opposed provision from FHLB Membership Eligibility Rule:

Credit unions scored a victory last week when the FHFA finalized its FHLB membership eligibility rule and removed a provision requiring credit unions to maintain a certain percentage of assets in mortgages throughout their membership in their bank. [Read More]

LSCU Aims for Advocacy Wins in Florida and Alabama:

The League has legislation in Florida to update the Deceptive and Unfair Trade Practices Act, to allow a credit union to register a central location to be served legal documents, and to allow credit unions to access the FHLB’s mortgage purchasing program. In Alabama, the League is pursuing legislation modernizing credit union investment authorities, modernizing the role of the credit committee, and adding a wild card provision to the state charter. [Read More]

Virginia League Pursues Charter Enhancement Legislation:

Bills supported by the Virginia League would permit credit unions to accept public deposits and modernize the state’s field of membership restrictions. [Read More]

MWCUA Brings Forward CU Modernization Legislation in Arizona:

Last week the Mountain West Credit Union Association (MWCUA) brought forth a credit union act modernization bill, H 2381, in Arizona. [Read More]

Over on the Removing Barriers Blog…

CUNA strongly opposes new HMDA reporting requirements… Representatives Royce and Pocan form the Congressional Cooperative Business Caucus… CFPB announced a field hearing on checking account access… NCUA Chairman Matz and CFPB Director Cordray announce a joint webinar… FASB likely to push credit impairment standard to Q2… CFPB announces application process for Credit Union Advisory Council… NCUA announces Initial Registry Period for CUSO Registry.

And Finally…

Very shortly, the CFPB will release a new proposed rule on small dollar payday loans, and this week, we took to The Hill newspaper to press the case that credit unions should be exempt from the proposal. Check out the op-ed here.

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