ARLINGTON, Va.–NAFCU has sent a comment letter to the Treasury Department in response to its newly published “Report on Nonbank Financials, Fintech, and Innovation.
As CUToday.info earlier reported here, Treasury said in releasing the report that it is seeking to identify improvements to the regulatory landscape it says will “better support nonbank financial institutions, embrace financial technology, and foster innovation.”
NAFCU’s response addressed a number of issues in the report, including:
Small-Dollar Lending
“NAFCU supports exempting credit unions from the Bureau’s Payday Rule. NAFCU also supports efforts by the National Credit Union Administration to promote responsible short-term, small-dollar installment lending through its payday alternative loans (PALs) program. NAFCU has encouraged the Bureau to work with the NCUA to accommodate more flexible PALs options,” said NAFCU President and CEO Dan Berger.
Debt Collection
“We support efforts by Treasury to achieve transparency in the debt collection marketplace while recognizing that first-party debt collectors, such as credit unions, are already held to high standards and subject to the Bureau’s existing authority to regulate unfair, deceptive, and abusive debt collection practices,” said Berger.
TCPA
“NAFCU supports Treasury’s recommendation that Congress make certain statutory changes to the TCPA,” wrote Berger.
Payments
“NAFCU generally agrees with Treasury’s approach for achieving more secure payments,” said Berger.
Remittances
“NAFCU supports efforts to grant more flexibility with respect to issuance of Regulation E disclosures. NAFCU also advises raising the current 100 transfer per annum threshold for applicability of the remittance transfer rule’s safe harbor exemption,” said Berger.
Data Sharing and Section 1033 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act)
“NAFCU is optimistic that innovation-focused efforts to promote flexible use of disclosures will translate into modernization of existing disclosure and advertising requirements, which have often proven inflexible and unwieldly in an increasingly digital environment,” wrote Berger.
Data Security and Breach Notification
“NAFCU agrees with Treasury that future legislation should protect consumer data while recognizing existing federal data security requirements for financial institutions, such as credit unions,” said Berger.
New Credit Models
“NAFCU supports Treasury’s view that regulators, through interagency coordination, should tailor regulation and guidance to enable the increased use of new credit models and data sources. NAFCU generally agrees that regulators should permit 'prudent experimentation' and accommodate innovation through the use of new approaches to supervision and oversight,” said Berger.
Regulatory Review of Outdated Regulations and Electronic Signatures
“NAFCU supports Treasury’s recommendation that financial regulators should periodically review existing regulations as innovations occur and new technology is developed to determine whether such regulations fulfill their original purpose in the least costly manner,” said Berger.