CUNA Advocacy Update

In case you’re keeping score at home… The House and Senate are in recess and will return next week.  Twenty-three state legislatures are in session this week; twenty-three have already adjourned and 4 do not have sessions this year.

CFPB Arbitration Hearing Thursday: We expect that the proposed rule for arbitration clauses will be released in conjunction with this hearing. [More]

CFPB to Reopen TRID/KBYO Rule in Response to CUNA Advocacy: In response to months of advocacy, last week the CFPB sent a letter to industry trade associations, including CUNA, to announce that it will initiate a rulemaking in late July 2016 to address many of the ongoing issues and concerns over the implementation of the TILA/RESPA Integrated Disclosures (TRID) or Know Before You Owe (KBYO) rules. [More]

CUNA Criticizes OTR and Operating Fee Schedule Methodologies: Last week, we filed a comment letter on NCUA’s Request for Comments on the Administration Operating Fee Schedule Methodology and the Overhead Transfer Rate (OTR) Methodology. CUNA has long advocated for full transparency and open communication regarding the overhead transfer rate with the credit union community.  We commend the NCUA for opening up for comment the OTR and the Operating Fee Schedule, and further urge the NCUA to continue allowing for notice and comment prior to amending or changing the OTR methodology in the future.  Nevertheless, our letter reflects our consistent opposition of any overhead transfer of agency expenses to the National Credit Union Share Insurance Fund (NCUSIF) that are not legitimate, substantiated, “insurance-related” costs, consistent with fairness to state and federal credit unions and the FCUA. [More]

FASB Finalizes Credit Impairment Changes: The Financial Accounting Standards Board (FASB) agreed last week on final changes to its accounting standard for determining credit impairment on loans and other financial instruments. At its meeting, the Board decided to push back by one year the effective date tentatively agreed on during a meeting last fall; the original proposal did not set forth a possible effective date. Following today’s decision, the impairment standard will be effective for credit unions (and other private companies) for annual periods beginning after December 15, 2020, and interim periods within fiscal years beginning after December 15, 2021. This is a big win for CUNA, which urged FASB to provide credit unions with at least three years (from issuance of a final standard) to comply with the changes. [More]

FHFA Hearing on “Duty to Serve” Features Credit Union Perspective:  CUNA and other credit union representatives, including Jerry Reed, President/CEO of Member First Mortgage, were present at a roundtable on the Federal Housing Finance Agency’s (FHFA) rulemaking on their “Duty to Serve” rules for Fannie Mae and Freddie Mac. The hearing focused on how the rules could improve the distribution and availability of mortgage financing for residential properties that serve very low, low, and moderate-income families in underserved markets.  The FHFA is considering various alternative approaches in evaluating the enterprise’s performance under the Duty to Serve rules. [More]

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:

Issue Comment Period Deadline

Agency

CUNA Staff Contact
Draft National Strategy for Financial Literacy Update May 11, 2016 Treasury Luke Martone
Amendments to Servicing Rules under TILA/RESPA May 26. 2016 CFPB Andy Price
Fixed Assets June 27, 2016 NCUA Lance Noggle

Over on the Removing Barriers Blog CUNA thanks Senator Reed for leadership on financial literacy… CUNA, Maryland and District of Columbia credit unions offer recommendations to CFPB’s HMDA implementation team… House passes resolution of disapproval of DoL fiduciary rule… CFPB publishes student loan tool kit… FFIEC agencies propose revisions to Uniform Consumer Compliance Rating System.

And, finally… If you’ve heard me speak at a League or credit union function over the last few years, you’ve certainly heard the story of the 80th Congress, the one that President Truman dubbed the “Do-Nothing” Congress. That Congress enacted 7.5% of the bills introduced; today’s Congress is on pace to enact just over 1.5%. Business Insider published an article this week based on the 2015 work of a group of researchers analyzing the rise of partisanship in the House of Representatives. Take 60 seconds to view this video that shows how the House of Representatives has become hyper-partisan over the last 70 years.  The full research report is here.

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