WASHINGTON—CUNA is recommending that the Bureau of Consumer Financial Protection delegate to the NCUA primary examination and enforcement of consumer protection laws for credit unions with over $10 billion in assets.
That is one recommendation among several CUNA made in a comment letter to the Bureau in response to the BCFP’s latest Request for Information (RFI) on enforcement processes.
The letter addresses several improvements that the Bureau should make. Specifically:
“CUNA supports [transferring examination and enforcement authority] as it will enable the Bureau to fully focus its examination and enforcement efforts on Wall Street banks and other abusers of consumers, while ensuring credit unions continue to be adequately supervised by the federal agency most proficient with its structure and operation,” the letter reads.
Should the Bureau retain examination and enforcement over credit unions with over $10 billion in assets, CUNA stresses the importance of synergy with the NCUA as a partner throughout the investigation and enforcement process.
The additional considerations mentioned in the letter were:
- The Bureau must not impose enforcement actions that are not supported by prescriptive laws, regulations, or guidance under its jurisdiction
- If the Bureau continues primary examination and enforcement over the largest credit unions, then its processes must be more transparent and directed at resolving any violations, with enforcement actions serving as a last resort
- The Bureau should establish for the financial services industry a matrix for how it determines civil money penalties. This matrix should be published for notice and comment