WASHINGTON–NAFCU meet with representatives of the CFPB yesterday, while CUNA has sent a letter to the Fed with concerns over withdrawals from savings.
Ahead of a meeting with the CFPB yesterday, NAFCU’s Carrie Hunt told CUToday.info the trade group would continue to advocate for a full exemption from CFPB payday lending rules for credit unions that participate in NCUA’s PALs program.
“Ultimately, credit unions are taking steps to fill a void for consumers,” Hunt said.
Hunt said in meetings to date, CFPB Director Kathy Kraninger has shared views “more in line with our view on regulation, which is to take more of a scalpel approach rather than broad regulations to root out” bad actors.”
Hunt said NAFCU was also seeking to discuss CFPB proposals around HMDA and third-party debt collection.
CUNA Letter to Fed
Separately, in advance of proposed rulemaking by the Fed, CUNA sent a letter to the Board of Governors of the Federal Reserve System expressing concerns regarding the board’s current limit of six transfers per month from a savings account, as outlined in Regulation D.
“We believe such threshold is arbitrary, antiquated, and unnecessary,” the letter reads. “At the very minimum, the Board should increase the transfer limit to at least 25 transactions per month… [W]e believe it is long overdue for the Board to update this limit that has its roots in the early 1980s.”
CUNA’s position is that the current limit under Regulation D limits consumers’ control over their funds, and places them at risk for diminished overdraft protection should an overdrafted checking account attempt to pull funds from a savings account that has met its monthly limit on transfers.
CUNA noted Section 204.2(d) of the Board’s Regulation D (Reserve Requirements of Depository Institutions) establishes a limit of six transfers per month from a consumer’s savings or money market account when made by various “convenient” methods, such as an electronic or online transfer. Under the current framework, after the sixth withdrawal or transfer, consumers may only access their funds through an ATM or an in-person visit to their financial institution.
The full CUNA letter can be found here.