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Calling All CUs! Please Comment on CFPB's Small Dollar, Vehicle Title, Payday Loan Proposal by Oct. 7
Wednesday, October 5, 2016 7:00 AM

Cornerstone and the Consumer Financial Protection Bureau need to hear from you!

Cornerstone is still actively soliciting credit unions to comment on the CFPB's most recent proposal on small-dollar, vehicle title, and payday loans. We anticipate that if the rule were to pass as written, it would greatly impact many loan products, especially short-term, small loans, and those that refinance existing vehicle loans. All credit unions are requested to send in their comments as soon as possible. Need help? Visit our compliance site here.

The proposed rule would heavily regulate most loans under 45 days and certain loans with a term of more than 45 days (that exceed a rule-determined “all-in APR” or 36 percent). Loans covered by this rule would be subject to an ability-to-repay analysis during the underwriting process, along with certain collections, tracking, and reporting requirements. The rule provides several limited exceptions for loans over 45 days, including a partial but not complete exemption for National Credit Union Administration’s payday alternative lending (PAL) program. 

Only 40 out of 500 credit unions in the region, including one unaffiliated credit union, have sent comment letters, which are due to the CFPB on Friday, Oct. 7. We offer our sincere thanks to the following credit unions that have responded to our call to action and sent comment letters:

Abilene Teachers FCU
Access Community CU
American Airlines FCU
America's CU
Amplify FCU
Arkansas Health Center FCU
Arkansas Superior FCU
Centex Citizens CU
Chemcel FCU
Combined FCU
Communication FCU
Corner Stone CU
Doches FCU
Electric Cooperatives FCU
First Central CU
First Class American CU
Garland County Educators' FCU
HSU FCU
Jackson County FCU
Las Colinas FCU
Liberty County Teachers FCU
Matagorda County CU
Members Choice CU
Members Financial FCU
Muskogee FCU
Oklahoma Employees CU
Pine FCU
RGVCU
River City FCU
San Angelo FCU
Santa Fe FCU
Southland FCU
Southwest 66 CU
Tarrant County's CU
Temple CU
Texas Community FCU
Texas Workforce CU
Texhillco School Employees FCU
UP Arkansas FCU
Ward County CU

More information on the proposal can be found in CUNA’s detailed analysis of the proposal and through a recording of CUNA’s webinar on the rule, free for members. 

If you need help in crafting comment letters, or if you have questions about this proposal, please contact Cornerstone Credit Union League SVP Regulatory Compliance Suzanne Yashewski at syashewski@cornerstoneleague.coop or 512-853-8516.