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Regulatory Advocacy

Working Together to Reduce Regulatory Burdens
Regulatory Advocacy brings the voice of credit unions to federal and state regulators. Our Regulatory Advocacy staff is committed to establishing and maintaining effective working relationships with regulators to ensure credit unions’ issues and concerns are heard.

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.

OVERDRAFTS SURVEY
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.

 

PowerComment

An interactive online tool designed to empower credit unions to participate in the regulatory process.

PowerComment allows you to:

  • Find up-to-date and easily digestible information on proposed compliance rules. This feature provides a summary of pending regulations to help you identify potential operational, financial, and member service impacts of proposed rules.
  • Participate in deeper discussions to increase your understanding of proposed regulatory rules. Ask fellow PowerComment users or League staff questions related to current proposed rules.
  • Write a comment letter to regulators. Convey your thoughts, opinions, and concerns regarding proposed rules. Whether your comments support or oppose a proposed rule – let the regulators know.

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.

From the Editors of CU Weekly

California Department of Business Oversight (DBO) Commissioner Jan Owen (left center) discusses important state-chartered credit union issues with credit union CEOs at a joint roundtable between the California Credit Union League and DBO.
DBO, CEOs COVER IMPORTANT CU TOPICS
updated 05/23/16 05:30 PM
Plus: NCUA, FASB, CFPB Updates
The California Credit Union League and California Department of Business Oversight (DBO) co-hosted a League member- only joint CEO Roundtable earlier this month, which provided an open forum for CEOs to hear from and be heard by DBO Commissioner Jan Owen and her staff—including Scott Cameron, senior deputy commissioner for the division of financial institutions, and Bert McLane, credit union chief examiner.

The following are highlights from the meeting:

  • Low Income Credit Union Designation—The low income credit union (LICU) designation process was discussed with the DBO noting it will affirm an LICU designation by letter if a credit union meets the criteria established under federal law ( see DBO’s March bulletin). When questioned about the Member Business Lending (MBL) cap exemption for LICUs, the DBO stated its process now includes automatic exemption of the MBL cap for LICUs, which is the same for federal credit unions. If an existing LICU has an exemption from the MBL cap with a limit, or does not have an exemption, it can write to the commissioner to receive a new letter allowing the credit union to operate under the new rule—a full MBL cap exemption. The DBO will use the examination process to monitor an LICU’s management of its MBL program. Owen said it is her desire to be less prescriptive and let CEOs manage their credit unions.
  • NCUA’s New MBL Rule—Regarding the National Credit Union Administration’s (NCUA) new MBL rule, the DBO will follow the new principles-based rule and examine credit unions accordingly. Training for state examiners is expected in fourth-quarter 2016, in time for the Jan. 1, 2017 effective date.
  • Credit Union Assessments 2016-2017—The DBO expects to increase the assessment rate by 5 cents for the 2016-2017 assessment. When the DBO first looked at its budget and found it underfunded, the potential increase was much higher. Owen thanked the Credit Union Advisory Committee for its continual hard questions that forced the DBO to go back to the finance department and figure out a different solution. As a result, the DBO received authority to spend an additional $1.8 million from the reserve fund, which minimized the increased costs to credit unions.
  • Timely Responses—When asked about monitoring of response times, the DBO acknowledged the need for improvements. It is working on improving the application monitoring system to get better data and reports that will be reviewed internally. Owen encouraged CEOs to contact her via email if they have not received a timely response on a request and are still waiting.
  • Examinations (Scott Cameron and Bert McLane discussed exam focus and trends)Interest rate risk: a net long term ratio on the high side will cause an examiner to look more closely at how IRR is modeled, management’s strategy, etc. Loan growth: if examiners see significant loan growth, they will look more closely to ensure there is a strategic reason and properly managed rather than a loosening of underwriting. BSA/AML: it was suggested the DBO also ensure finance companies they supervise also follow BSA requirements, as it places credit unions at a competitive disadvantage when they do not. Sensitivity: adding an S to the CAMEL rating for sensitivity was discussed, noting the examiners would evaluate balance sheet makeup and how it is managed. It was suggested examiners should look at both increasing rates and long-term flat rates. It was also strongly suggested the DBO refrain from dictating how a credit union should structure their balance sheet. Communication: it was suggested that DBO examiners begin their engagements by asking CEOs, What are your biggest concerns?. Owen encouraged everyone to complete post-exam surveys and to be candid. The survey is a valuable tool.
  • Staffing updates—The deputy commissioner of credit unions position is still vacant, with no candidates at this time.
  • Credit Union Advisory Committee—There is one vacant seat on the committee with several other terms expiring in June. If you are interested in being a member of the seven-person committee, send Owen a letter of interest and include your biography. The committee meets quarterly to dialog with the agency, informing them of what’s going on in the field, and to be a sounding board to the agency. The recent efforts on the potential assessment increase is one example of the committee’s work.

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Archive of Past Comment Letters

The Leagues write letters in response to proposed legislation and regulations that affect your credit union’s ability to serve members.