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Comments on No-Action Letters, MLA, Flood Loan Regs Due This Month
Friday, December 5, 2014 6:40 AM

Comments on military lending, the National Credit Union Administration's flood insurance proposal, and the Consumer Financial Protection Bureau's policy on no-action letters are due this month.

The deadlines are:

  • Dec. 15:  CFPB no-action letters. The proposal could help financial institutions discover where new products fit with existing statues and regulations. If the new product or service promises "substantial" consumer benefit and there is uncertainty about how existing CFPB regulations would apply, bureau staff could send a letter advising the organization that the bureau will not recommend action on the matter in question;
  • Dec. 26: Department of Defense's Military Lending Act changes. The proposal would cap the military annual percentage rate of interest on certain credit products at 36%. Comments were originally due in November, but the comment period was extended an additional 30 days after several requests were made; and
  • Dec. 29: NCUA loans in flood hazard areas. The proposal, issued jointly by federal regulators and the Farm Credit Administration, would amend the agencies' regulations regarding loans in areas with special flood hazards by implementing provisions of the Homeowner Flood Insurance Affordability Act of 2014. Comments are due to the Credit Union National Association by Dec. 19.

Comments on the NCUA's proposed corporate credit unions rule are due just after the New Year, on Jan. 5. The agency would amend the rule to "streamline and clarify certain provisions" and provide some regulatory relief. CUNA is also collecting comments on the proposal until Dec. 30.