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.
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.
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.
|Department of Defense (DOD)||DOD Proposed Rule re Military Lending Act||12/26/14|
|National Credit Union Administration||NCUA Proposed Interagency Flood Insurance Rule||12/29/14|
|National Credit Union Administration||NCUA Proposed Rule on Corporate Credit Unions||01/05/15|
|Federal Housing Finance Agency (FHFA)||FHFA Proposed Regulation on Federal Home Loan Bank Membership||01/12/15|
|Internal Revenue Service||IRS Proposal to Remove the 36-Month Non-Payment Testing Period Rule||01/13/15|
|Addressing attendees of the California Credit Union League’s 2014 Government Relations Rally in Sacramento (L-R): Jan Owen, Commissioner for the California Department of Business Oversight (DBO), and Erick Orellana, Deputy Commissioner of Credit Unions for DBO|
When asked about the processing time for Credit Union Owned Life Insurance (CUOLI) applications, Orellana indicated a decision and response to a credit union should take no more than five weeks once DBO receives a complete application.
In a February bulletin sent to credit unions, the DBO stated that, “with the proper due diligence and controls in place, and when installed as part of a well-developed and specialized financing strategy, the DBO generally does not object to the use of CUOLIs.” However, the department expects credit union boards of directors “to exercise reasonable care, skill, and caution when performing its pre-purchase analysis of any such investments.”
Additional guidance is included in the bulletin, including liquidity and concentration risks. The DBO views any concentration of CUOLI in excess of 25 percent of a credit union’s net worth to be a concern. This 25 percent limit is in line with the 2004 Federal Financial Institutions Examination Council (FFIEC) guidance. To view the entire posting, click here and scroll down to the CUOLI Investments for Credit Unions section of February’s posted bulletin.
Orellana also gave an update on the financial health of state-licensed credit unions, and how the department is working with credit unions every day. State-licensed credit unions hold a little more risk than the average credit union in California, but they are “stable and strong,” and financial data keeps improving, Orellana said.
“It’s crucial you are here and tell your story,” Owen said the day before credit union leaders met with state legislators. With respect to questions for the DBO, “we have an open-door policy, and we expect to hear from you,” she said. “We’re here to help.”