CUNA Advocacy Update

CFPB Proposed Rule on Small Dollar, Short Term Lending Released Last Week: The CFPB has proposed a complicated (and long) proposal on short term, small dollar lending. The rule should be aimed at curtailing predatory practices in the market, but unfortunately also sweeps in credit union consumer friendly loans in addition to payday loan programs. As we noted last week, it is going to take some time to analyze what the new proposal would require and how it will effect credit union lending if not modified to remove regulatory burdens. We have committed to credit unions that we will provide a thorough and accurate analysis, not rushed and sloppy work. After all, it serves no one if the early analysis of this proposal’s impact provides credit unions with imprecise or hyperbolic information. Nevertheless, we do have some initial thoughts on how the CFPB has approached this proposal and what credit unions should consider as we evaluate the impact on these lending programs. [More]

Payday Proposal Will Impact State Laws: Our State Governmental Affairs staff takes a look at the CFPB proposal’s impact on state laws in this Removing Barriers Blog post.

Congress Returns for June Session: The House and the Senate return to Washington for what is expected to be the last full month of session of the year. The House is expected to consider H.R. 4775, the Ozone Standards Implementation Act of 2016; H.R. 5325, the Legislative Branch Appropriations Act for 2017; H.R. 5278, the PROMESA Act (Puerto Rico Debt Crisis); H. Con. Res. 89, Expressing the sense of Congress that a carbon tax would be detrimental to the United States economy; and H. Con. Res. 112, Expressing the sense of Congress opposing the President’s proposed $10 tax on every barrel of oil.

The Senate is expected to consider a motion to proceed to S.2943, the National Defense Authorization Act.

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


  • The Senate Banking, Housing and Urban Affairs Committee will hold a full committee hearing on “Bank Capital and Liquidity Regulation.”


  • The House Small Business Committee Economic Growth, Tax and Capital Access Subcommittee will hold a hearing on “Bearing the Burden: Over-regulation’s Impact on Small Banks and Rural Communities.” CUNA will submit a letter for the record of the hearing presenting the results of our recently finalized regulatory burden study.
  • The House Education and the Workforce Committee will hold a full committee hearing on “The Administration’s Overtime Rule and Its Consequences for Workers, Students, Nonprofits, and Small Businesses.” CUNA will submit a letter for the record of the hearing describing the impact that this regulation would have on America’s credit unions.
  • The Senate Small Business and Entrepreneurship Committee will hold a full committee hearing on “No More Hikes: Small Business Survival Amidst Unaffordable Flood Insurance Rate Increases.”

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:


Comment Period Deadline


CUNA Staff Contact

Student Loan Borrower Communications

June 12, 2016


Luke Martone

NCUA Occupancy Rule

June 27, 2016


Lance Noggle

Uniform Interagency Consumer Compliance Rating System

July 5, 2016


Andy Price

Joint Incentive Based Compensation Rule

July 22, 2016


Lance Noggle

2016 Regulatory Review

August 8, 2016


Lance Noggle

Arbitration Clauses

August 22, 2016


Leah Dempsey

Hensarling Expected to Outline Regulatory Reform Effort: In a speech tomorrow at the New York Economic Club, House Financial Services Committee Chairman Jeb Hensarling (R-TX) is expected to unveil a new financial reform initiative. The effort is expected to include a community financial institution section, which could feature more than two dozen regulatory relief bills for community financial institutions, including the “Financial Institutions Examination Fairness and Reform Act (H.R. 1941),” the “Taking Account of Institutions with Low Operational Risk Act (H.R. 2896),” the “Portfolio Lending and Mortgage Access Act (H.R. 1210),” and the “Financial Institution Customer Protection Act (H.R. 766).” While this legislation has little chance of moving through the legislative process this year, it is likely to serve as an important part of the agenda of the committee into next year. [More]

House Financial Services Committee Releases June Schedule: House Financial Services Committee Chairman Jeb Hensarling (R-TX) released the committee’s schedule for the month of June. It includes several meetings of the Committee’s task force on terrorism financing, a mark-up of pending legislation during the week of June 13, and the semi-annual Humphrey-Hawkins hearing featuring testimony from Janet Yellen, Chairman of the Federal Reserve Board of Governors.

Over on the Removing Barriers Blog CUNA/World Council oppose expanded FATCA reporting requirements… NCUA to host webinar on MLA changes… CUNA reiterates TCPA concerns in comment on FCC’s Implementation of the Budget Act.

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