CUNA Advocacy Update

Washington is digging out from one of the biggest winter storms in history. The government closed on Friday and remains closed today. The House cancelled its session for the week; the Senate postponed its session until Wednesday. The bankers turn on grassroots in opposition to NCUA’s Field of Membership proposal; the comment deadline is two weeks from today. Prize-linked savings legislation has been enacted in New Jersey. NCUA votes to publish OTR methodology. All of this and more in this week’s CUNA Advocacy Update…

Bankers Attack NCUA’s Field of Membership Proposal:

It was only a matter of time. ABA and ICBA have launched grassroots in opposition to NCUA’s Field of Membership proposal. We have reports that as many as 500 letters from bankers have been sent to NCUA, and more could be on the way. We always knew the bankers would try to influence the comment process, and their activity serves as an important reminder that we need to continue to make our voice heard. Last 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.

The bankers also sent their missives to Congress, and CUNA will be sending a response this week once the government opens. We will identify the factual inaccuracies in the bankers’ message and expose their disturbing perspective that Americans should have less access to affordable financial services. Look for coverage of our response in next week’s report. 

CUNA’s FOM Comment Letter in Development:

CUNA’s comment letter is being drafted right now. Over the last few weeks, we’ve held meetings with groups of CUNA members to make sure their concerns are included, and those meetings will continue this week. If you have points or perspective you hope we will include in our comment letter, please share them with Elizabeth Eurgubian or me this week, as we intend the file our letter in advance of the deadline. 

House Snowed Out:

The blizzard forced the House of Representatives to cancel this week’s session. The House will meet next on February 1.

Senate Plans Nomination Vote and Energy Bill:

The Senate will return to session on Wednesday and conduct a vote on a judicial nomination. Later in the week, the Senate is expected to consider S. 2012, the Energy Policy Modernization Act. The Senate Finance Committee had planned a Tuesday hearing on “Helping Americans Prepare for Retirement: Increasing Access, Participation and Coverage in Retirement Savings Plans.” We will keep an eye on when that hearing will be rescheduled.

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, 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
EGRPRA Review March 22, 2016 NCUA Andy Price

New Jersey League Scores Win on Prize-Linked Savings Bill:

Governor Chris Christie signed League-championed legislation, S 2495, that permits New Jersey credit unions and other financial institutions to offer savings promotions, also known as prize-linked savings (PLS) programs. [Read More]

Payments Remain Hot Topic in the States:

With less than a month into the 2016 legislation session, states are grappling with payments. State actions range from hearings regarding chip-and-PIN to bills on data breach notification and interchange fees. [Read More

NCUA Votes to Publish Overhead Transfer Rate Methodology:

At its meeting last week, the NCUA Board issued a Final Rule amending Part 790.2(b) related to the Office of Minority and Women Inclusion Reporting Structure. The NCUA also voted to publish NCUA’s 2017-2021 Strategic Plan, the Overhead Transfer Rate Methodology and the Federal Credit Union Operating Fee Methodology in the Federal Register for Public Comment. [Read More]

Over on the Removing Barriers Blog…

FCC responds to court challenge of TCPA Order… CUNA tells Senate Homeland Security Committee that credit unions are a better option for the underserved than postal banking… NCUA and Treasury commit to double the number of CDFI credit unions… CUNA pushes back on FinCEN Customer Due Diligence proposal.

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