CUNA Advocacy Update

So much is going on this week that it’s hard to know where exactly to begin. CUNA-supported legislation ending Operation Choke Point will be considered in the House. The CFPB will hold a field hearing on checking accounts. FASB will hold a meeting on its CECL proposal, days after 62 Members of the House sent it a CUNA-supported letter. Leagues across the country have pro-credit union legislation introduced in state legislatures… oh, and there’s this little matter about Field of Membership: the comment period on NCUA’s FOM modernization proposal is Monday. It’s time to submit your comment letter!

All of this and more in this week’s CUNA Advocacy Update… 

FOM Comments Due in 1 Week:

We are getting ready to submit CUNA’s FOM comment letter. Thank you to everyone who provided feedback, suggestions and concerns. Please take some time this week to consider how the FOM proposal would benefit your credit union, and submit a comment to NCUA. It’s important to hear from all credit unions, including state chartered credit unions. To submit your comment letter, please go to PowerComment

The bankers have turned up the heat with hundreds of comment letters coming in to NCUA. They’ve also made their voice heard on Capitol Hill. We sent a letter to all House and Senate offices last week rebutting their factually inaccurate letter. 

Choke Point Legislation on Tap in House:

After cancelling votes last week because of the blizzard, the House of Representatives returns today to consider bills under suspension of the rules. Later this week, the House is expected to consider the “Financial Institution Customer Protection Act of 2015 (H.R. 766). This is CUNA-supported legislation to end Operation Choke Point, a Department of Justice program aimed at encouraging banks and credit unions to terminate accounts of gun dealers, adult shops and other similar businesses. For more information on this, please take a look at this post from CUNA’s CompBlog and our testimony before Congress from 2014.

The House will also consider the “Housing Opportunity through Modernization Act of 2015” (H.R. 3700); and the “Encouraging Employee Ownership Act of 2015” (H.R. 1675). The Senate will continue consideration of the “Energy Policy Modernization Act of 2015” (S. 2012).  

Trio of Hearings in House Financial Services Committee:

On Tuesday, the House Financial Services Committee will hold a full committee markup of the committee’s views and estimates on the budget for FY2017. Also on Tuesday, the House Financial Services Committee Oversight and Investigations Subcommittee will hold a hearing on “Unsustainable Federal Spending and the Debt Limit.” The Committee will conclude its hearings this week with a Wednesday hearing in the Task Force to Investigate Terrorism Financing Subcommittee on “Trading with the Enemy: Trade-Based Money Laundering is the Growth Industry in Terror Finance.” 

CFPB Hearing on Access to Checking Accounts:

On Wednesday, the CFPB will hold a field hearing on access to checking accounts. The hearing will be held in Louisville, Kentucky, and Sandy Tallarico-Gogan of Park Community Credit Unionis expected to testify. 

CUNA-Supported CECL Sign-On Letter Earns Support of 62 House Members:

The Financial Accounting Standards Board (FASB) is in the final stages of reviewing a proposed standard that would drastically change the accounting method for assessing credit impairment. The proposal would require a forward-looking “current expected credit loss”—or CECL—model instead of the current “incurred loss” approach. This new standard would require credit unions to hold additional capital well above their current loan loss reserves—a requirement that will have significant consequences on lending in communities. For the last several months, CUNA has been working closely with ICBA to raise awareness of this issue in Congress, and we worked with Representatives Scott Tipton (R-CO) and Patrick Murphy (D-FL) to organize a Congressional sign-on letter to FASB, encouraging the standards setting body to delay finalization of the rule.   

Later this week, Susan Hannigan, SVP & CFO at Jeanne D’Arc Credit Union and Luke Martone, Senior Director of Advocacy and Counsel, will participate in a meeting at FASB to discuss this issue. This will be the third meetings we’ve had with FASB on this issue. 

Leagues Leading the Waqy in State Capitols:

By the close of this week, legislatures in 41 states will be in session and after only a month into the 2016 session, over 29,000 bills have been introduced in the states. Several credit union leagues have already had bills introduced to remove barriers for credit unions to better serve their members. In Indiana, the League is pursuing legislation fixing an outdated restriction on lending to board members. Massachusetts, Michigan and Wisconsin continue their pursuit of charter update legislation. In Florida, the League of Southeastern Credit Unions seeks to protect credit unions through an improved process service requirement. Public deposit legislation is advancing in Virginia, Ohio and New York. The Georgia League seeks legislation to clarify that lawyers do not need to be present in the lending process; Georgia also held a successful GAC meeting last week. In Arizona, the League is pursuing legislation to modernize director compensation and governance requirements. In Missouri, the Heartland Credit Union Association has asked the legislature to make changes in the state credit union act to provide parity with federally chartered credit unions.

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:

**IMPORTANT** 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

HMDA Resubmission Guidelines

March 14, 2016 CFPB Andy Price
Enterprise Duty to Serve Underserved Markets March 17, 2016 FHFA Andy Price
EGRPRA Review March 22, 2016 NCUA Andy Price

Over on the Removing Barriers Blog…

Department of Labor’s Fiduciary rule is now in its final stages, but we’re not giving up – last week, we sent a letter to NCUA urging the agency to engage on this issue as well as the overtime proposal. 

And finally…

As a member of the Electronic Payments Coalition (EPC), CUNA works closely with other financial services groups to protect interchange and insist on strong security standards for all payments participants. The EPC is out this morning with results from a survey conducted by Morning Consult indicating that consumers want choices in the payment security space, not a mandate like chip and pin. 

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