WASHINGTON—In response to the COVID-19 pandemic and its effect on members and credit union operations, NAFCU President and CEO Dan Berger has sent letters to NCUA and the CFPB calling for broad flexibility with compliance for at least 60 days.
The NAFCU letters follow similar letters sent earlier by CUNA making similar requests.
In the letter Berger said credit unions have proactively worked to keep their staff, members and families safe while ensuring there is no disruption to vital financial services, and he urged NCUA and the CFPB to support the efforts with regulatory guidance.
The Specifics
Specifically, in the letter to NCUA, Berger said as long as credit unions' actions are in the spirit of the Federal Credit Union Act, “NAFCU asks that the NCUA allow credit unions flexibility in determining how best to comply with member meeting requirements, whether that means permitting virtual meetings or flexibility with rescheduling annual meetings."
“Various state and local governments, including the state of Washington, have recommended halting all large group gatherings,” Berger wrote. “Credit unions face the dilemma of non-compliance if they abide by government recommendations and hold virtual-only meetings. However, if a credit union holds an in-person meeting the health and safety of attendees is at risk."
Berger further stressed the importance of the agency addressing compliance with regulations that credit unions may find difficult or impossible to comply with due to proactive measures they have taken, such as abiding by federal government health and safety recommendations.
Letter to CFPB
Meanwhile, in the letter to CFPB Director Kathy Kraninger, Berger said the Bureau should consider both immediate and longer-term actions to support business continuity, such as assuring credit unions and other financial institutions they will not be penalized for the steps they take to assist consumers on an expedited basis or through social distancing procedures.
Berger also suggested that, to enhance the speed at which loan modifications and other applications are processed (such as requests for emergency credit), the Bureau should seek to alleviate disclosure-related compliance burdens. The Bureau may also seek to accommodate efforts to “expedite the processing of consumer applications and implement social distancing policies, even if the cost of such speed and adaption is a trivial reduction in accuracy.”