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At the Leagues

The Leagues

California & Nevada

Regulatory Advocacy

Working Together to Reduce Regulatory Burdens
Regulatory Advocacy brings the voice of credit unions to federal and state regulators. Our Regulatory Advocacy staff is committed to establishing and maintaining effective working relationships with regulators to ensure credit unions’ issues and concerns are heard.

The Regulatory Advocacy area keeps you informed of the latest proposed rules and regulations, their potential impact on credit unions, and provides comments to regulatory agencies to help shape regulations and lessen the compliance burden. 

Overdrafts Survey

We URGENTLY need ALL credit unions to participate in an extremely important survey.

The Leagues are conducting a survey to obtain information about credit unions’ overdraft and courtesy pay programs. The survey results will be shared with the CFPB and provide them with fact based information to help inform their rulemaking and prove what we know to be true, credit unions are the best choice for consumers.

The survey was sent on Monday, November 3, 2014 to all member CEOs whose credit unions offer checking accounts. Please look for your email and complete the survey by Friday, November 21, 2014.

Click here for more information about the survey.

Click here for blank pdf copy of the survey. You can use this copy to review the questions and compile your responses.

Integrated Mortgage Disclosures – Resources Available

Your League, CUNA, and the CFPB want to ensure you have the necessary information and resources to successfully implement the CFPB’s rule on Integrated Mortgage Disclosures under RESPA/TILA. The rule is effective Aug. 1, 2015.

In addition, we want to hear from you about any issues that may conflict with or impede implementation of the new disclosures, particularly after you have discussed implementation with your vendors and settlement service providers. Will they be ready?

Click here for information about the Integrated Mortgage Disclosures rule, the resources available to you, and a request for feedback.

 

PowerComment

An interactive online tool designed to empower credit unions to participate in the regulatory process.

PowerComment allows you to:

  • Find up-to-date and easily digestible information on proposed compliance rules. This feature provides a summary of pending regulations to help you identify potential operational, financial, and member service impacts of proposed rules.
  • Participate in deeper discussions to increase your understanding of proposed regulatory rules. Ask fellow PowerComment users or League staff questions related to current proposed rules.
  • Write a comment letter to regulators. Convey your thoughts, opinions, and concerns regarding proposed rules. Whether your comments support or oppose a proposed rule – let the regulators know.

Educate yourself on proposed rules and regulations that affect your credit union and take the opportunity to comment! Visit www.powercomment.org to get started today.

From the Editors of CU Weekly

QM LOANS WON'T VIOLATE ECOA, REG B
updated 10/25/13 11:40 AM
Agencies Release Joint Statement
Five federal regulatory agencies have issued a joint statement in response to inquiries from creditors about whether they would be liable under the disparate impact doctrine of the Equal Credit Opportunity Act (ECOA) and its implementing regulation, Regulation B, by originating only Qualified Mortgages under the Ability-to-Repay and Qualified Mortgage Standards Rule that takes effect Jan. 10.

These agencies recognize that some creditors might be inclined to originate all or predominantly Qualified Mortgages, particularly when the Ability-to-Repay Rule first takes effect. They also recognize lenders’ concerns that doing so may be at odds with the ECOA and Regulation B.

The agencies' joint statement clarifies their position that the requirements of the Ability-to-Repay Rule and ECOA are compatible, in that creditors may act "on the basis of their legitimate business needs."

Given this, "The agencies do not anticipate that a creditor's decision to offer only Qualified Mortgages would, absent other factors, elevate a supervised institution's fair lending risk," the statement said.

The joint statement was issued by the Board of Governors of the Federal Reserve System (FRB), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corp. (FDIC), National Credit Union Administration (NCUA), and the Office of the Comptroller of the Currency (OCC).

The NCUA, OCC, FRB, and FDIC also included a statement that the same principles apply in supervising institutions for compliance with the Fair Housing Act (FHA) and Housing and Urban Development's (HUD) implementing regulation, 24 C.F.R. Part 100.5. Each of these agencies has supervisory authority as to FHA.

"The California and Nevada Credit Union Leagues are pleased with the joint statement," said Sharon Lindeman, vice president of regulatory advocacy for the Leagues. "This decision will ease at least one compliance concern for credit unions as they make important decisions about their product offerings and compliance with the January 2014 Qualified Mortgage Rules."

Click here to read the multi-agency statement.

 
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Archive of Past Comment Letters

The Leagues write letters in response to proposed legislation and regulations that affect your credit union’s ability to serve members.