CUNA Advocacy Update – Week of August 14, 2017

What’s Happening in Washington this Week

The House and Senate remain in recess and will both return on September 5th.  However, that doesn’t mean that Washington is quiet.  Your CUNA advocacy team is meeting with Congressional staff regarding regulatory relief, tax reform, and appropriations legislation.  You can get involved and use this month to meet with your Representative and Senators while they are at home in your states. A concerned constituent is the best lobbyist!

Successful NCSL Legislative Summit in Boston!

Representatives of CUNA, credit union leagues, AACUL and CUNA Mutual joined more than 5,000 attendees in Boston at the National Conference of State Legislatures (NCSL) Legislative Summit to promote credit union awareness.
Engagement at the NCSL Legislative Summit is particularly important because legislators adopt policies in NCSL’s standing committees.  The adopted policies become the backbone of NCSL’s efforts to fight unwarranted federal preemption of state laws, unfunded mandates, and federal legislation that threatens state authority and autonomy. [Read more here]

CUNA Files Three Comment Letters with the NCUA

CUNA continues its work with the NCUA to communicate credit union concerns with the proposed merger rule, to eliminate or reduce any regulatory burden that could result from updated rules.  Last week, CUNA filed three comment letters with the NCUA.  The letters were in response to NCUA proposed rules to update the agency’s voluntary merger rule, appeals for material supervisory determinations and appeals procedures. [Read more here]

CUNA Offers Suggestions as Part of NCUA’s Annual Regulatory Review

CUNA sent a letter to the NCUA in regard to the Office of General Counsel’s list of regulations scheduled for review this year. In the letter, CUNA reminded the NCUA that the cumulative regulatory burden on credit unions is at an all-time high and urged the NCUA to promulgate new or expand existing rules only if such rules are clearly warranted based on a compelling need. Similarly, the agency should strongly consider the current regulatory burden on credit unions as it proceeds with this and future regulatory reviews. [Read more here]

CUNA Urges CFPB to Delay Prepaid Rule Effective Date

CUNA sent a letter to the CFPB in response to proposed amendments to the prepaid accounts rule under Regulations E and Z.  While CUNA supports the Bureau’s attempt to provide flexibility related to the prepaid rule, the relatively narrow application of the proposed revisions will provide only limited relief. [Read more here]

Dear Colleague Letter Seeks to Exempt Credit Unions from Dept. of Defense MLA Rule

House Armed Services Committee Member Cook (R-CA) circulated a Dear Colleague letter that would request the Dept. of Defense exempt credit unions from its Military Lending Act regulation, as amended in July 2015.  CUNA greatly appreciates Rep. Cook’s effort to achieve relief for credit unions regarding the onerous requirements of the rule. [Read more here]

DOL Court Filing Indicates it is Seeking an 18-Month Delay for Fiduciary Rule

The Department of Labor (DOL) filed a brief last week indicating that it is proposing an 18-month delay for its Fiduciary rule. The DOL has sought comment on many aspects of the rule over the past several months. CUNA has sent several comment letters urging the DOL to delay the applicability of the Fiduciary rule to give credit unions time to resolve any additional compliance ambiguities. CUNA has also supported additional research efforts to ensure that credit union members are not harmed by unintended consequences of overly broad rules, and additional analysis about whether choices may be limited for moderate or low-income consumers. [Read more here]

Pending Regulatory Comments Calls

CUNA plans to comment on the following pending regulatory proposals. For our comment letters 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 for each proposal with your feedback.

For more information regarding these proposals, please follow the links below:

Issue Comment Period Deadline Agency CUNA Staff Contact
Annual Regulatory Review Aug. 14, 2017 NCUA Luke Martone
Amendments to Prepaid Accounts Rules under Regs E and Z Aug. 14, 2017 CFPB Luke Martone
Corporate Credit Unions Sept. 1, 2017 NCUA Luke Martone
Requirements for Insurance: NCUSIF Equity Distributions Sept. 5, 2017 NCUA Lance Noggle
Closing Corporate Stabilization Fund and Setting NCUSIF Normal Operating Level Sept. 5, 2017 NCUA Lance Noggle
2018-2020 Enterprise Housing Goals Sept. 5, 2017 FHFA Elizabeth Eurgubian
Small Business Lending Market Sept.14, 2017 CFPB Leah Dempsey
Defining and Delimiting the Exemptions for Employees Sept. 25, 2017 DOL Leah Dempsey
Emergency Mergers–Chartering and FOM Sept. 29, 2017 NCUA Elizabeth Eurgubian
Mortgage Disclosure Requirements under TILA (Reg Z) Oct.10, 2017 CFPB Elizabeth Eurgubian
Interesting Reads 

Posted in CUNA, NCUA.