CUNA Advocacy Update – Week of August 21, 2017

What’s Happening in Washington this Week

Pennsylvania creates CFPB-like unit within AG’s office

Pennsylvania Attorney General Josh Shapiro announced the launch of a Consumer Financial Protection Unit designed to “better protect Pennsylvania consumers from financial scams.”

The Unit will be led by Nicholas Smyth, who was an early CFPB employee and served as assistant director of the Office of Attorney General’s Bureau of Consumer Protection (the precursor to the CFPB). Smyth also helped draft the Consumer Financial Protection Act of 2010 (Title X of the Dodd-Frank Act), which created the CFPB. Among the cases that Smyth worked on while at the CFPB were ones involving auto lender Drivetime, ITT Educational Services and U.S. Bank’s MILES Program, an auto finance program for military service members. [Read more here]

FHFA Responds to CUNA Inquiry about Alternative Credit Scoring Models

In response to a letter sent by CUNA and other financial services trades back in February, the Federal Housing Finance Agency (FHFA) offered an update to their alternative credit score model project, noting the complexity of the analysis and that no changes would go into effect prior to the implantation of the Common Securitization Platform in mid-2019.

If the FHFA decides ultimately to allow the voluntary use of these alternative credit scoring models by credit unions and other lenders, it would mean that loans underwritten would be “conforming” for purposes of sale to the GSEs, and could expand mortgage credit opportunities for certain borrowers. Balanced against this interest is the need for strong mortgage underwriting, so it is important that potential alternative scoring models are demonstrated to be closely correlated with likelihood of repayment. [Read more here]

NCUA Releases Regulatory Reform Plan for Public Comment

The NCUA released a package of possible regulatory reforms that could be implemented over a four year time period. According to the agency, the reforms were recommended by an internal NCUA task force. CUNA has also recommended many of the proposed changes to the agency through meetings and regulatory review comment letters. The agency’s regulatory reform task force was created earlier this year after NCUA voluntarily chose to comply with the spirit of Executive Order 13777, which requires federal agencies to conduct regulatory reviews. [Read more here]

CFPB Launches New Web Form for Regulatory Inquiries

The CFPB announced a change to the process for submitting questions to the Bureau on regulations. The new web form is available here and replaces the email address which was previously used by the CFPB to accept questions and suggestions. [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
Revised Overhead Transfer Rate Methodology Aug. 29, 2017 NCUA Lance Noggle
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.