Comments on Flood Insurance, QM, Reg Z; Upcoming FHFA Session

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Comments are due in the coming weeks on multiple regulatory proposals that will affect credit unions, including the following:

  • Sept. 4: Federal financial regulator proposed guidance on interagency questions and answers regarding flood insurance.
  • Sept. 8: The Consumer Financial Protection Bureau’s (CFPB) proposed amendments to the general Qualified Mortgage definition.
  • Sept. 21: The CFPB’s proposal to exempt certain insured depository institutions and insured credit unions from the Regulation Z requirement to establish escrow accounts for certain higher-priced mortgage loans.
  • (COMMENT PERIOD CLOSED) Aug. 31: The National Credit Union Administration’s (NCUA) request for information on strategies for future examination and supervision utilizing digital technology.
  • (COMMENT PERIOD CLOSED) Aug. 31: The Federal Housing Finance Agency (FHFA) is seeking comments on a new regulatory capital framework for Fannie Mae and Freddie Mac consisting of risk-based capital and leverage ratio requirements.
  • (COMMENT PERIOD CLOSED) Aug. 31: The Federal Communications Commission’s (FCC) proposed revisions to its rules to implement the Telephone Consumer Protection Act and the TRACED Act. These involve certain requirements for voice service providers.

FHFA Listening Sessions on Re-Proposed GSE Capital Rule
​To allow interested parties to elaborate on their public comment letters on the re-proposed capital rule for Fannie Mae and Freddie Mac, the Federal Housing Finance Agency (FHFA) will host listening sessions on Sept. 10 (at 7 a.m. Pacific) and Sept. 14 (at 7 a.m. Pacific). These listening sessions are opportunities for interested parties to elaborate on specific subjects and do not substitute for formal comment letters.
Interested parties were allowed to submit comments on the notice of proposed rulemaking until Aug. 31 via They were also allowed to request a speaking slot and/or register as an attendee at one of the upcoming listening sessions here.

Nevada’s Eviction Moratorium Update
For Nevada credit unions, Nevada Gov. Steve Sisolak extended the state’s eviction moratorium by 45 days according to a news release from the governor's office.

The moratorium was originally set to expire on Sept. 1. The extension will allow for counties to pay out short-term rental assistance to landlords, provide the courts more time to implement the newly-created residential eviction mediation program and develop electronic filing options, and allow the State of Nevada to continue making progress on reducing the backlog of unemployment claims.

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