WASHINGTON–Among several letters CUNA sent to Congress and regulators Wednesday, the trade association is asking the CFPB to re-issue for public comment changes to Regulation CC (Expedited Funds Availability Act) issued by the Federal Reserve in 2011.
The proposed changes would update Reg CC regarding the availability of funds and collection of checks. CUNA noted that while the Fed used to have complete authority over Reg CC, the CFPB now has rulemaking authority over certain aspects of it, including those addressed in the proposal.
“As described in detail in CUNA’s comment letter to the Fed on the proposal, we have significant concerns that the proposal would substantially increase fraud-related and compliance costs if adopted,” the CUNA letter reads. “The Dodd-Frank Wall Street Reform and Consumer Protection Act provided the CFPB with rulemaking authority over certain aspects of Regulation CC, including those in the Fed proposal. Therefore, we urge the Bureau to review our comment letter, which includes recommendations to improve the proposed changes.”
CUNA added that the proposed changes were issued by the Fed more than six years ago, and that it is encouraging all agencies to finalize proposals on any topic in a shorter timeframe than six years; ideally, within one year at most.
The letter was signed by Luke Martone, CUNA’s senior director of advocacy and counsel.
Full Funding For CDFI Fund
Separately, CUNA and 68 certified Community Development Financial Institution (CDFI) credit unions wrote to Congress Wednesday to strongly support full funding for the Treasury's CDFI Fund at $248 million for Fiscal Year (FY) 2018, the same amount Congress appropriated for FY 2017.
"CDFIs such as Community Development Credit Unions are charged with supplying low-income, distressed communities with traditional banking services such as savings accounts and personal loans, and offering individuals the tools needed to become self-sufficient stakeholders in their own future," the letter reads. "The CDFI Fund uses small amounts of federal dollars to leverage significant amounts of private and non-federal dollars, and has added a tremendous boost to the CDFI industry."
The letter highlights two examples of CDFI credit unions leveraging funds to make an impact in their communities:
- Appalachian Community FCU, Johnson City, Tenn., used a $2.1 million CDFI grant to provide $10,500 down payments for over 200 families in its community to become first-time home buyers
- St. Louis Community CU, St. Louis, which leveraged and $849,000 grant into $22.7 million in auto loans through a program to provide affordable car loans to low- and moderate-income individuals and families so they can have access to reliable transportation to get to and from work.
"These examples represent just two credit unions and how the CDFI Fund is being used to grow local economies and serve the most economically distressed communities in the nation," the letter reads. "Fully funding the CDFI Fund at $248 million is a good investment by the federal government. Good paying jobs lead to more tax revenue and less dependence on the federal social safety net."
Other letters CUNA sent Wednesday:
- Letter to Senate appropriators asking for CDFI funding, CDRLF funding and to keep any language placing NCUA under appropriations out of any bills.
- Letter of support for H.R. 2954, the Home Mortgage Disclosure Adjustment Act. The bill would provide regulatory relief from some Home Mortgage Disclosure Act (HMDA) reporting requirements by raising the reporting threshold for certain pieces.
- Letter of support for H.R. 3758, the Senior Safe Act of 2017. The legislation would provide legal immunity for properly trained financial services employees who disclose concerns about financial exploitation of senior citizens.