WASHINGTON—Members of CUNA’s Consumer Protection Subcommittee met with NCUA and the Consumer Financial Protection Bureau this week, addressing a wide range of issues related to regulatory burden.
Attendees, which represented credit unions of varying asset sizes and memberships, provided specific examples to NCUA and CFPB about how members have been harmed by overly burdensome regulations that have inhibited credit unions’ ability to serve them, CUNA explained.
“As an example, they highlighted to CFPB how it has become more difficult, particularly for smaller credit unions, to continue to operate in the mortgage market compared with the largest financial institutions. They also provided solutions for an improved Home Mortgage Disclosure Act (HMDA) rule and urged CFPB to delay the implementation of the rule,” CUNA said.
The attendees, which included CUNA staff, discussed:
- Implementation of the Military Lending Act
- CFPB's payday and small-dollar loan proposal
- CFPB’s third-party Small Business Regulatory Enforcement Act (SBREFA) proposal for debt collection, and potential pending first-party debt collection SBREFA process
- Unfair, deceptive or abusive acts or practices (UDAAP), including CFPB’s recent enforcement action against a credit union
- Issues relating to HMDA
- Overdraft protection services
The meetings are part of coordinated efforts by CUNA and member credit unions to advocate against regulatory burden, the trade association stated.
“In both meetings, subcommittee members urged CFPB and NCUA to better collaborate, so that credit unions are not unfairly penalized by CFPB proposals or enforcement actions that conflict with NCUA guidance or statutory rights under the Federal Credit Union Act,” CUNA said. “They urged the regulators to work closely on any policymakings surrounding debt collection, particularly since collection activities are directly connected to safety and soundness requirements. They warned that overly stringent debt collection requirements on credit unions could harm members, if credit unions are forced to constrict providing credit.”
The subcommittee also questioned NCUA whether the impact of potential enforcement actions on the National Credit Union Share Insurance Funds has been considered, CUNA said.
The group expressed additional concerns about CFPB’s proposed payday and small-dollar loan proposed rule, which could detrimentally impact credit unions’ consumer-friendly programs. The credit unions offered appreciation to NCUA for its support of the Payday Alternative Loan (PAL) program, and for sending a letter to the CFPB urging it to exempt the PAL program and to make other changes to its proposal, the trade association said.