Amplify Your Voice on Important Regulatory Issues

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Several important issues and proposed rules are currently open for comment. Regulators want to hear from you on these issues, and the California and Nevada Credit Union League wants to make it easy for you to do so.

Check out these issues you can take action on through PowerComment.

Consumer Financial Protection Bureau (CFPB): Remittances Rule
The CFPB is proposing to increase the safe harbor threshold in the remittances rule related to whether a person makes remittance transfers in the normal course of its business.

The bureau proposes to increase the threshold from 100 transfers to 500 transfers annually. This change would have the effect of reducing compliance costs for credit unions that make a limited number of remittance transfers.

The bureau is also proposing changes to mitigate the effects of the expiration of a statutory exception that allows insured institutions to disclose to consumers estimates of the exchange rate and covered third-party fees instead of exact amounts. That exception expires on July 21, 2020.

Both of these proposed changes are significant and will reduce compliance costs for a significant number of credit unions. The California and Nevada Credit Union Leagues have long advocated for increasing the threshold from 100 to 500 (or higher) and continuing to allow estimates.

Comments are due Jan. 21, 2020.

National Credit Union Administration (NCUA): Real Estate Appraisals
The NCUA Board (Board) proposes to increase the threshold level below which appraisals would not be required for real estate transactions secured by a single 1-to-4 family residential property from $250,000 to $400,000.

Consistent with the requirement for other transactions that fall below applicable appraisal thresholds, federally insured credit unions would be required to obtain written estimates of market value of the real estate collateral that is consistent with safe and sound banking practices in lieu of an appraisal. 

The proposal is consistent with the banking agencies’ final rule, effective on Oct. 9, 2019, that increased the residential appraisal threshold level for banks from $250,000 to $400,000.

Comments are due Jan. 28, 2020.

CFPB: TRID Rule Assessment
The CFPB is requesting public comment on its plans for assessing the TRID Rule. In November 2013, the CFPB issued a final rule titled “Integrated Mortgage Disclosures under the Real Estate Settlement Procedures Act (RESPA or Regulation X) and the Truth In Lending Act (TILA or Regulation Z)’’ (commonly referred to as the TRID Rule). The Bureau amended the 2013 rule on two occasions before its effective date on October 3, 2015.

The Bureau is required to assess each significant rule adopted by the Bureau under Federal consumer financial law. The Bureau must also publish a report of the assessment not later than five years after the effective date of such rule.

Therefore, the Bureau is requesting public comment on its plans for assessing the TRID Rule as well as comments on recommendations for modifying, expanding, or eliminating the rule.

Comments are due Jan. 21, 2020.

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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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