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||Proposed Delay of Integrated Mortgage Disclosures Rule Under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z) and Amendments||07/07/15|
|National Credit Union Administration||NCUA Share Insurance - IOLTAs||07/13/15|
|Consumer Financial Protection Bureau||CFPB Seeks Input on Student Loan Servicing||07/13/15|
|National Credit Union Administration||NCUA Regulatory Review (2015)||08/03/15|
Everything you need to review the rules' specific provisions, submit a comment letter, and effectively communicate your credit union's opinion to the NCUA is available at PowerComment!
Capital Planning and Stress Testing Proposal
While this proposed rule only applies to credit unions with assets of $10 billion or more (covered credit unions), there are aspects all credit unions should be aware of, including the proposal's cost to the National Credit Union Share Insurance Fund (NCUSIF) and public disclosure. Credit unions should provide their comments.
Under the proposal, covered credit unions must submit a capital plan to NCUA annually, perform specific capital analysis, and have board oversight of their planning and analysis.
In addition, NCUA would conduct independent stress-testing of covered credit unions and require these credit unions to maintain a 5 percent stress test capital ratio. NCUA estimates the first-year cost would be $4 million ($1 million for each of the four applicable credit unions with more than $10 billion in assets)—an expense that would be charged to the NCUSIF.
NCUA is also requesting comment on whether the stress test results should be made public.
Joint Agency Flood Insurance Proposal
This proposed rule would establish escrow requirements for flood insurance payments, require lenders to accept private flood insurance coverage, and clarify that lenders have the authority to charge for forced-placed flood insurance coverage.
Use PowerComment TODAY
In today’s regulatory climate, it is imperative credit unions are engaged in the comment process. Regulators need to hear from you on how a proposed rule will impact your credit union, your members, and the credit union movement.
Credit unions are encouraged to use PowerComment to make their voice heard on these proposed rules, as well as others!