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.
RISK-BASED CAPITAL - 2nd Proposal
The Leagues have launched an RBC2-dedicated webpage, containing the latest updates, analysis, and communications about how RBC2 may impact your credit union.
Click here to access the Leagues’ RBC2 webpage.
During CEO roundtable discussions this summer, it was decided we must take a proactive approach regarding likely rulemaking by the Consumer Financial Protection Bureau (CFPB) on overdraft programs. Initiating the first step the Leagues conducted a survey in December 2014 to obtain information about credit unions’ overdraft and courtesy pay programs.
In January, California and Nevada credit union leaders met with the CFPB Assistant Director of Financial Institutions Dan Smith to share the survey results with the bureau and discuss concerns regarding the possible regulation of overdraft plans by the CFPB.
Click here for more information about the overdraft survey and to access the survey results (accessible to League members only).
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.
An interactive online tool designed to empower credit unions to participate in the regulatory process.
PowerComment allows you to:
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.
|Consumer Financial Protection Bureau||Amendments to the 2013 Mortgage Servicing Rules under RESPA (Reg X) and TILA (Reg Z)||03/16/15|
|National Credit Union Administration||NCUA's Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA) Regulatory Review||03/19/15|
|Consumer Financial Protection Bureau||Prepaid Accounts||03/23/15|
|National Credit Union Administration||Capital Planning and Stress Testing – Schedule Shift||03/27/15|
|Consumer Financial Protection Bureau||Amendments Relating to Small Creditors and Rural or Underserved Areas||03/30/15|
|Consumer Financial Protection Bureau||CFPB Proposed Safe Student Account Scorecard||03/30/15|
|National Credit Union Administration||NCUA's Risk Based Capital Proposal (RBC2)||04/27/15|
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."