CUNA Advocacy Update

CUNA Meets with CFPB to Discuss Small Dollar Rule:

CUNA staff met last week with key policymakers at the CFPB to discuss the Bureau’s proposed rule on small dollar loans. During the meeting CUNA staff raised concerns about the fact that the CFPB’s proposal sweeps in consumer friendly loans such as National Credit Union Administration (NCUA) PAL loans, small-dollar loans offered by state-chartered credit unions that vary in structure, and auto refinance loans. [More]

CFPB Releases Debt Collection SBREFA Proposals Aimed at Third Party Collectors:

CUNA is still in the early stages of reviewing recently released proposals from the CFPB relating to a Small Business Review panel on debt collection. These proposals were released in anticipation of a Small Business Review Panel, and are not a formal Proposed Rule. While the CFPB has said the proposals are aimed at third-party debt collectors, we still have some initial concerns that the proposals will also impact credit unions who have a relationship with third-parties. [More]

Exam Flexibility Initiative Moves Forward:

The National Credit Union Administration continues to accept public comments on how it can improve its examination and supervision procedures and process. [More]

Oral Arguments Set for TCPA Order Challenge:

Oral arguments for the lawsuit challenging the Federal Communication Commission’s July 2015 Telephone Consumer Protection Act (TCPA) Order have been set for October 19, 2016. CUNA, along with the American Bankers Association and Independent Community Bankers Association, filed the financial services joint amici brief in support of litigation in the U.S. Court of Appeals for the District of Columbia, which is challenging the FCC’s TCPA Order. [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.

CFPB Proposes Fixes to TRID Rule:

The Consumer Financial Protection Bureau (CFPB) issued a number of CUNA-requested clarifications Friday to its Truth in Lending Act-Real Estate Settlement Procedures Act integrated disclosure (TRID) rule. The original rule went into effect on October 3 last year and was a major overhaul of the closing process. CUNA has been urging the CFPB to make many changes that became readily apparent once implementation of the rule commenced. Comments are due Oct. 18 and we will be reaching out to all members for input as well as providing a comprehensive summary of the proposal. [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:


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

America’s Credit Unions Fully Engaged at American Legislative Exchange Council Meeting:

With Congress and most state legislatures out of session, the two leading state legislator associations have been hosting their annual gatherings. America’s Credit Unions are actively participating in both. [More]

Understanding the CFPB’s Ex Parte Policy:

When you are at the CFPB and someone discloses that the ex parte rules may apply, don’t be intimidated. You can actually embrace this policy, knowing that it means you are going to have your say, and also that you are talking to a decision-maker who must document the conversation. [More]

Programming Note:

CUNA’s Advocacy Update will not publish regularly until September 6, 2016. If circumstances warrant, we will send a special edition of the Advocacy Update; otherwise, look for the next one in early September. In the meantime, you can find the latest advocacy information on the Removing Barriers Blog, which will be updated regularly throughout the August recess.

Posted in Advocacy News, CUNA.