WASHINGTON—Credit unions support the goals of section 1071 of the Dodd-Frank Act, but are concerned about increased costs, CUNA wrote to the House Small Business Subcommittee on Economic Growth, Tax, and Capital Access.
The subcommittee conducted a hearing on the CFPB’s 1071 rule this week.
“We are concerned about potential unintended consequences and substantial costs in complying with the creation of a broad data collection where one does not currently exist,” the letter reads. “In addition, as entities bound to serve a specific field of membership, credit union data would likely be incomparable to other lenders.”
Revisions Urged
CUNA urged the CFPB to consider several revisions to the proposed rule, including:
- Increasing the covered financial institution threshold to at least 500 covered credit transactions in each of the two preceding calendar years coupled with a size-based exemption for entities of $600 million assets or less
- Reducing the gross annual revenue threshold used to determine which businesses are “small businesses” for purposes of the rule to no more than $1 million in gross annual revenue in the preceding fiscal year
- Exempting several types of credit transactions from the definition of covered credit transactions, including agriculture-purpose credit, HMDA-reportable transactions, consumer-designated credit, loans under $50,000, and government guaranteed loans
- Excluding credit line increases from the definition of covered application for purposes of the rule
- Considering the firewalling requirement’s potential for negative impacts on smaller lenders serving business borrowers
- Reduce the section 1071 data set to only data points that are statutorily required and avoid unnecessary discretionary data points
- Rescinding the requirement for covered financial institutions to conduct a visual observation and surname analysis on applicants declining to provide responses to demographic questions
- Considering the privacy and reidentification concerns in finalizing the rule and conduct a notice and comment period on the bureau’s “balancing test” for publication of 1071 data
- Adopting a phased mandatory compliance schedule that begins no sooner than three years following the issuance of a final rule
CUNA Named a Top Workplace in Wisconsin
Separately, CUNA has been awarded a Top Workplaces 2023 honor by The Wisconsin State Journal, the third time the organization has received the honor.
The list is based on employee feedback gathered through a third-party survey administered by Energage, an employee engagement and workplace improvement research firm, CUNA said.
“At CUNA, we strive to create an inclusive work culture that supports our people and reflects our organizational values and the ‘people helping people’ philosophy of the credit union movement,” said CUNA President/CEO Jim Nussle. “What makes this recognition rewarding is that it’s our own employees telling us they see that effort and it’s making a difference.”
CUNA is currently in the process of moving its physical workspace in Madison, Wis. from the CUNA Mutual campus to Madison Yards, a 21-acre mixed use development that includes office space, medical space, retail, restaurants, a hotel and a Whole Foods. The development is less than three miles from CUNA’s current offices.
The Top 5%
About 1,500 Madison-area companies were nominated by their employees and CUNA is listed among the top 5% of employers. Organizations of all sizes participated in the survey, which measured key drivers of engaged cultures such as leadership, strong values, clear direction, and motivated workers, the trade group stated.
“How we work and collaborate has changed so rapidly in the last few years that it’s required all of us to pay even more attention to employee well-being and ensure we don’t leave anyone behind,” said CUNA EVP/Chief Operating Officer Jill Tomalin. “We have a mission-driven work culture to help credit unions advance financial well-being for all, and we’ve always believed that mission is only successful if it starts at home with our own employees. For these reasons, this recognition feels especially validating for CUNA.”
Nussle was also interviewed by the Wisconsin State Journal on CUNA's culture.
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