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 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|
|National Credit Union Administration||Small Entity Definition||05/04/15|
|Consumer Financial Protection Bureau||Credit Card Market Review||05/18/15|
|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.”