CUNA Advocacy Update

I hope everyone has recovered from the big game last night! Field of Membership comment letters are due today. NCUA appears to be moving toward an extended exam cycle. CUNA members represent the credit union system before CFPB and FASB meetings. Federal Reserve Chair Yellen will testify before Senate and House committees. The Gun Lobby is taking aim at credit unions and banks in state capitols. Oh, and Congress is back in session for the last week before the GAC… 

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

FOM Comments Due Today:

It’s not too late to submit a comment letter in support of NCUA’s Field of Membership proposal. Folks, it’s important that you comment on this proposal. Last week, we saw a number of letters in opposition to the proposal posted on NCUA’s website. We knew all along that the bankers would try to make their voice heard; that’s why we’ve been encouraging everyone in the credit union system to do the same. Today is the final day to submit comments. To do so, please go to PowerComment

CUNA sent our comment letter up last week, fully supporting the proposal and identifying ways we believe NCUA could go even further under the law. Thank you to everyone who provided feedback, suggestions and concerns. For more information regarding our letter, please see this post on the Removing Barriers Blog. 

NCUA Appears to Be Moving toward an Extended Exam Cycle:

Paul Gentile, Chairman of CUNA’s Examination and Supervision Subcommittee, and CUNA staff met last week with NCUA staff to continue to press the agency on examination frequency and fairness issues. This meeting is a precursor to a meeting with the full subcommittee at the Governmental Affairs Conference.

CUNA Member Testifies at CFPB Hearing on Access to Checking Accounts:

CUNA and the Kentucky Credit Union League were proud to a have member–Sandy Gogan, senior vice president of Retail Operations at Park Community Credit Union–testify last week at a CFPB hearing on access to checking accounts. Sandy did a fantastic job highlighting how credit unions offer products and services that help members manage finances, and noting that overdraft protection and financial education programs can be important services for members.

CUNA Member Tells FASB How CECL Proposal May Hurt Credit Unions:

Susan Hannigan, SVP and CFO of Jeanne D’Arc Credit Union in Lowell, MA told the Financial Accounting Standards Board (FASB) Thursday that its “current expected credit loss” (CECL) proposal would adversely impact credit unions, and encouraged FASB to use a simpler message than what has been proposed. At the meeting, representatives of FDIC and the Federal Reserve indicated they would accept a simpler method; while NCUA staff were present at the meeting, they did not speak, so we sent a letter to NCUA Board Chairman Debbie Matz on Friday encouraging her to echo the assurances from the banking regulators.   

This remains a critical issue for credit unions, and it is one that CUNA has been working on for several years. In recent weeks, CUNA worked closely with ICBA to raise awareness of this issue in Congress, and to encourage Members of the House of Representatives to join Representatives Scott Tipton (R-CO) and Patrick Murphy (D-FL) on a Congressional sign-on letter to FASB, encouraging the standards setting body to delay finalization of the rule.

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
NCUA Draft 2017 – 2021 Strategic Plan March 28, 2016 NCUA Lance Noggle
BSA CTR Revised Layout & Additional Data Fields April 4, 2016 FinCEN Luke Martone
Overhead Transfer Rate Methodology April 26, 2016 NCUA Andy Price
Operating Fee Methodology April 26, 2016 NCUA Andy Price

In Congress:

The House is expected to consider the “Debt Management and Fiscal Responsibility Act of 2015” (H.R. 3442); the “Common Sense Nutrition Disclosure Act of 2015” (H.R. 2017); and the “Scientific Research in the National Interest Act” (H.R.3293).  

The Senate will continue consideration of the “Energy Policy Modernization Act of 2015” (S. 2012).  

As usual, we are following several hearings on both sides of the Capitol, including the following; 


The House Financial Services Committee will hold a full committee hearing on the Federal Reserve’s semi-annual Monetary Policy Report to Congress. Federal Reserve Board of Governors Chair Janet Yellen will testify. 


The House Financial Services Committee Housing and Insurance Subcommittee will hold a hearing on “The Future of Housing in America: Examining the Health of the Federal Housing Administration.” 

The Senate Banking, Housing and Urban Affairs Committee will hold a full committee hearing on “The Semi-annual Monetary Report to Congress.” Federal Reserve Board of Governors Chair Janet Yellen will testify. 

The House Financial Services Committee Subcommittee on Financial Institutions and Consumer Credit will hold a hearing on “Short-term, Small Dollar Lending: The Consumer Financial Protection Bureau’s Assault on Access to Credit and Trampling of State and Tribal Sovereignty.” CUNA will submit a statement for the record of this hearing.

State Legislatures Hit Their Stride:

By the close of this week, legislatures in 42 states will be in session, leaving only Arkansas, Louisiana, Minnesota and North Carolina left to convene (Montana, Nevada, North Dakota and Texas do not have regular sessions in 2016). During the first full week of February, both New Mexico and Arizona introduced legislation that would benefit credit union members. In New Mexico, data breach legislation was introduced along with an Arizona bill that would permit credit unions to operate prize-linked savings programs.

Gun Lobby Takes Aim at Credit Unions and Banks:

CUNA’s Advocacy Team is also closely monitoring a state effort by the gun lobby to create a private cause of action against credit unions and other financial institutions for discrimination if they refuse to serve (or discontinue service to) firearm and ammunition businesses, even if the reason for refusal to serve is due to field of membership or member business lending constraints. 

Over on the Removing Barriers Blog…

House Committees consider legislation to alter fiduciary proposal… House of Representatives passes CUNA-supported Operation Choke Point legislation… DOD extends DMDC Deadline after CUNA’s request. 

And finally…

Today, CUNA welcomes Eli Joseph as Deputy Chief Advocacy Officer for Congressional Relations. Eli will help lead our advocacy efforts on Capitol Hill.   

Prior to joining CUNA, Eli worked for Merck & Co Inc, as Executive Director of Federal Policy and Government Relations. His professional background includes extensive trade association experience as Managing Director of Federal Government Relations at the Biotechnology Industry Association. Eli served on the staff of the Democratic Senatorial Campaign Committee and in the White House Office of Legislative Affairs in the Clinton administration. 

Eli holds a Master of Business Administration from the University of North Carolina at Chapel Hill and a Bachelor of Arts in Political Science and International Relations from the George Washington University.

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