Amplify Your CU's Voice on the Latest Regulatory Issues

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The California and Nevada Credit Union Leagues want to make it easy for you to comment on proposed rules and requests for information.

Check out the following issues that you can take action on through PowerComment:

NCUA: Combination Transactions with Non-Credit Unions
The National Credit Union Administration (NCUA) Board proposes to adopt new regulations (new Subpart D of Part 708a) to clarify and make transparent the procedures and requirements currently in place related to combination transactions. Combination transactions include those where a federally insured credit union (FICU) proposes to assume liabilities from a non-credit union, including a bank. They also include a FICU’s merger or consolidation with a non-credit union entity.  

Further, the proposed rule clarifies the scope of Part 741.8 of the NCUA’s regulations, which currently requires the NCUA to grant approval before a FICU may purchase loans or assume an assignment of deposits, shares, or liabilities from any institution that is not insured by the National Credit Union Share Insurance Fund (NCUSIF). 

Comments are due 60 days after publication in the Federal Register.

FHFA: Property Assessed Clean Energy (PACE) Programs
The Federal Housing Finance Agency (FHFA), as regulator for Fannie Mae and Freddie Mac (collectively, the Enterprises) as well as the Federal Home Loan Banks, is requesting information on residential Property Assessed Clean Energy (PACE) programs.

PACE programs are energy retrofitting programs financed through special state legislation enabling a ‘‘super-priority lien’’ over existing and subsequent first mortgages. This super-priority lien status and the resulting safety and soundness concerns is prompting the FHFA to seek input on potential changes to its policies for its regulated entities.

Due to the continued threat associated with super-priority PACE liens, this RFI requests comments regarding potential actions the FHFA may take regarding PACE liens, such as:

  • Decreasing loan-to-value ratios for all new loan purchases in states or in communities where PACE loans are available.
  • Directing the Enterprises to increase their Loan Level Price Adjustments (LLPAs) or require other credit enhancements for mortgage loans or refinancings in communities with available PACE financing.
  • Establishing safety and soundness standards for the FHLBs to accept as eligible advance collateral mortgage loans in communities where PACE loans are available.
  • Requiring servicers of mortgage loans for the Enterprises to provide an annual or more frequent notice to existing borrowers in PACE-eligible communities informing them that, under the terms of their mortgage, PACE liens are not permitted.

Comments are due March 16, 2020.

Log in to PowerComment today and let your voice be heard!

PowerComment provides vital and easily digestible information to keep you informed on proposed rules, allows online discussions to increase your understanding, and allows you to write and easily submit your personalized comment letter to regulators. With nearly 1,000 users across the country, representing more than 620 unique credit unions, PowerComment gives credit unions a voice in the regulatory process.

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