WASHINGTON--America’s Credit Unions said its analysis of the federal government's 2026 Unified Agenda identifies dozens of pending regulatory actions that could significantly affect credit unions, including potential changes involving open banking, anti-money laundering compliance, the Central Liquidity Facility and capital requirements.
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Many items on the agenda, ACU noted, correspond to priorities America’s Credit Unions has engaged regulators on, including:
Personal financial data rights reconsideration: The CFPB plans to take the appropriate rulemaking steps necessary to reconsider the November 2024 final rule implementing section 1033 of Dodd-Frank.
- America’s Credit Unions has advocated for a revised rule that would afford credit unions more flexibility to charge appropriate member fees and accommodate institutions who offer legitimate secondary uses of covered data.
Revisions to Customer Due Diligence (CDD) requirements: FinCEN intends to issue a proposal to revise its CDD requirements for financial institutions to account for the changes created by the beneficial ownership information (BOI) reporting and access requirements set out in the Corporate Transparency Act.
- America's Credit Unions urged FinCEN to issue a CDD proposal in a 2024 letter.
Central Liquidity Facility (CLF): NCUA is considering a proposal to make certain CLF rule changes adopted through interim final rules in 2020 and 2021 permanent while removing provisions that expired.
- America’s Credit Unions has advocated for updates to the CLF regulations, including a June letter urging improvements to the CLF to ensure it continues to function as a timely and accessible source of liquidity for credit unions.
Community bank leverage ratio modifications: The Federal Reserve, jointly with the Office of the Comptroller of the Currency and Federal Deposit Insurance Corporation, expects to invite comment on a proposal that would make adjustments to the community bank leverage ratio. While the rulemaking is not applicable to credit unions, the widely anticipated reduction in the CBLR from 9% to 8% may influence the NCUA’s calibration of its analogous Complex Credit Union Leverage Ratio (CCULR), ACU said.
- America’s Credit Unions submitted a letter to the NCUA advocating for a reduction in the CCULR to 8% last year.