WASHINGTON–CUNA has sent letters to both CFPB and Treasury with separate recommendations for improving rules and regulations.
CUNA sent a letter to the CFPB in response to its Request for Information (RFI) on its proposed assessment of the Ability-to-Repay and Qualified Mortgage Rule (ATR/QM Rule). In the letter, CUNA includes a number of suggestions on how the CFPB could improve the ATR/QM rule.
CUNA submitted comments to the CFPB on the proposed threshold changes to HMDA HELOC reporting. In the comment letter, CUNA acknowledges the CFPB's effort to decrease the burden on lenders with limited HELOC activity, but also asked the CFPB to consider further increasing the threshold beyond 500. The proposed rule would change the HMDA HELOC reporting requirements from 100 to 500 open-end mortgages for 2018 and 2019.
Separately, CUNA sent a letter (attached) to the U.S. Department of the Treasury outlining areas where the trade group said regulatory burdens are harming the ability of credit unions to serve their members. “The letter expressed concerned with the overall cost of compliance for credit unions from CFPB rules, outlines a number of suggestions for the Treasury to find a better balance between BSA/AML requirements and costs to small financial institutions, (and) notes that the federal government should strongly support Community Development Credit Unions and the NCUA’s Community Development Revolving Loan Fund,” CUNA said.
It also provides suggestions for Housing Finance reform, the Military Lending Act, and the Telephone Consumer Protection Act.
“We will continue to urge the Treasury to engage with other regulators to improve the operating environment for credit unions,” CUNA said.
The full CUNA letter to Treasury can be found in CUToday.info’s The Gov here.