CUNA Advocacy Update

Major Party Vice Presidential Nominees Have Strong Record of Credit Union Support:

Governor Mike Pence (R-IN), the Republican Vice Presidential Nominee, and Senator Tim Kaine (D-VA), who was selected by Secretary Clinton to be the Democratic Vice Presidential Nominee, each bring to their respective tickets a strong record of credit union support. [More]

70 Senators tell CFPB: We gave you 1022 exemption authority for a reason:

An overwhelming, bipartisan majority of 70 U.S. senators have added their voices to a letter calling on the CFPB to tailor its rulemakings to protect credit unions from regulatory burden. The combined advocacy efforts of CUNA and state credit union leagues brings the total congressional support from both chambers to 399 signers. [More]

Happy Birthday, CFPB:

As the Consumer Financial Protection Bureau (CFPB) marked its fifth year of existence last week, we sent a letter to Director Richard Cordray about our increasing concerns about regulatory burden resulting from the CFPB’s actions.

The letter reiterated that credit union members are becoming collateral damage in the CFPB’s attempts to regulate banks, lenders and other financial companies that actually caused the crisis and harm consumers. While we recognize that credit unions operate in a highly regulated industry and must bear the reasonable costs of regulation, the constant stream of burdensome regulations from CFPB impairs the ability of credit unions to fully serve their members.

The letter invited Cordray and other top CFPB officials to visit a credit union headquarters to get a firsthand view of the compliance process for the various new regulatory requirements. We believe that such a visit would give these regulators a broader perspective on the large effect even a minor regulatory change may have on a credit union’s operations, and the difficulty credit unions have had over the past five years absorbing, understanding, and implementing the thousands of pages of CFPB regulatory changes.

Our letter also requested that the CFPB more fully consider how regulations are making life more difficult for credit union members, and highlighted a few specific areas where the Bureau could improve its regulations going forward:

  • Tailor rules to the abusers of consumers by using its exemption authority to protect credit union members (more than 75% of Congress has written to the bureau requesting the same thing).
  • Analyze the cumulative impact of rulemakings on credit unions and their members, before finalizing or proposing any new regulation that would affect them.
  • Work more closely with other regulators, including the NCUA, in order to learn how recent regulations have impacted credit unions and their ability to provide consumer-friendly products and services.
  • Work to understand the credit union difference by visiting credit unions and becoming more familiar with their operation and how regulations, such as the new mortgage disclosure rules or the pending Home Mortgage Disclosure Act reporting requirements, affect day-to-day operations.

NCUA Takes Step to End 12-Month Exam Cycle:

At last week’s Board meeting, the NCUA Board removed two existing performance goals that measured annual exams within the 2014-2017 Strategic Plan and the 2016-2017 Annual Performance Plan:

  1. Examine all federal credit unions annually
  2. Examine all federally insured state credit unions with assets above $250 million annually

While this removal does not immediately change the examination cycle for credit unions, it does set the stage for later improvements as being contemplated by the Exam Flexibility Initiative. The NCUA will also need to remove the requirements from the National Supervisory Policy Manual. [More]

We Need Your Feedback Regarding the CFPB Small Dollar Loan and Arbitration Proposals:

We are currently seeking widespread feedback from credit unions about how the CFPB’s small dollar proposed rule and arbitration proposed rule could impact credit union operations and the ability to offer products and services. We will continue to educate the Bureau about problems both of these rules could cause for credit unions and their members. Please check out the comment call and send comments, questions or concerns to Leah Dempsey, Elizabeth Eurgubian, Andy Price or me.

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

2016 Regulatory Review

August 8, 2016


Lance Noggle

Annual Privacy Notice Requirements

August 10, 2016


Leah Dempsey

Request for Information: Modernizing Call Reports

August 15, 2016


Andy Price

Community Development Revolving Loan Program

August 22, 2016


Lance Noggle

Arbitration Clauses

August 22, 2016


Leah Dempsey

Payday Loans

October 7, 2016


Leah Dempsey

Request for Information: Payday Loans

October 14, 2016


Leah Dempsey

Over on the Removing Barriers Blog:

CUNA comments on multi-agency compensation proposal… CFPB extends comment period on small dollar (payday) loan proposal… CFPB announces debt collection hearing in Sacramento, California for this Thursday… State legislatures are outpacing Congress in terms of legislative productivity.

Posted in Advocacy News, CUNA.