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|
Some of the changes being considered are required under the Dodd-Frank Wall Street Reform and Consumer Protection Act. However, the CFPB is considering additional requirements, such as requiring institutions to include an explanation of rejected loan applications.
As a first step, the CPFB is convening a panel of small lenders (credit unions and community banks) to provide feedback on potential changes. This panel is required under law when a rule under development may have significant impact on a substantial number of small entities.
The CFPB will also seek feedback from industry and consumer groups, and is consulting with other federal agencies. Credit unions can expect a proposed rule later this year.
The California and Nevada Credit Union Leagues are reviewing the proposed changes and their impact, and will keep credit unions informed of the rulemaking process and their opportunity to comment.
Changes being considered by the CFPB are categorized as “Better Information” and “Better Collection.” Under the “Better Information” category, the CFPB is considering requiring the following information:
New HMDA Tool (Access to HMDA Information)
In addition, the CFPB also announced a new HMDA tool designed to provide the public easier access to mortgage data.