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|
California state-charted credit unions are required to obtain approval from the DBO prior to purchase of CUOLI products, as they are considered investments. A credit union’s pre-purchase analysis and ongoing measurement and management of CUOLI risks are critical.
CUOLI investments are used to recognize the long-term service of key employees or protect against the loss of key employees. Earnings from these investments may be used to offset related benefits expenses, recover up to the cost of the benefit itself, or fund other employee benefits.
The DBO believes CUOLI investments present potential volatility to a credit union’s earnings and net worth due to liquidity and other considerations. Therefore, the DBO also states that holding excessive CUOLI products represents an unsafe and unsound practice, and that concentration greater than 25 percent of a credit union’s net worth is a "concern." This 25-percent limit is in line with 2004 Federal Financial Institutions Examination Council (FFIEC) guidance.
The National Credit Union Administration (NCUA) is also reviewing the rules for CUOLI investments for federal credit unions. Currently, a federal credit union may purchase an otherwise impermissible investment to fund an employee benefit obligation as long as, among other regulatory requirements, there is a direct relationship between the investment and the employee benefit obligation it serves to fund.
The California and Nevada Credit Union Leagues will keep member credit unions posted on any proposed amendments.
For more information or updates related to CUOLI products, contact California and Nevada Credit Union Leagues Vice President of Regulatory Advocacy Sharon Lindeman at 909-212-6063 or firstname.lastname@example.org.