CFPB Rulemaking, Credit Impairment, FOM
Seeking every opportunity to enhance the operating environment for credit unions in 2016, the Credit Union National Association will be closely monitoring issues such as rulemakings coming out of the Consumer Financial Protection Bureau addressing overdraft, an upcoming credit impairment proposal as well as the National Credit Union Administration’s field-of-membership (FOM), and member business lending proposals.
“This year will likely bring much-needed regulatory relief for credit unions in the form of the NCUA’s field-of-membership and member business lending rules, but we’re monitoring a number of regulations that could add to regulatory burden as well,” said Elizabeth Eurgubian, CUNA’s deputy chief advocacy officer. “As we look ahead, CUNA will be working to ensure the credit union perspective is heard while these regulations come together, and we will be looking at opportunities for further relief.”
In a list updated last week, CUNA outlined 15 top regulatory issues it will be monitoring in 2016, what potential outcomes are and CUNA’s advocacy strategy.
The top five items on the list are:
- Financial Accounting Standards Board (FASB) credit impairment proposal. The proposal would likely require a number of credit unions to increase their allowance for loan and lease losses accounts.
- NCUA’s FOM proposal. CUNA strongly supports the proposal, which would give federal credit unions a broader menu of FOM options to respond to changes in the marketplace. The NCUA’s proposal contains several CUNA-suggested changes, and CUNA continues to urge credit unions to send meaningful comments before the Feb. 8 deadline;
- NCUA’s member business lending proposal. Proposed in June, the rule would give credit unions greater flexibility and autonomy in offering commercial loans. CUNA strongly supports the proposal and awaits the final rule;
- Potential proposed rule on overdraft protection and a Small Business Review panel from the CFPB. CUNA is very concerned about a potential rulemaking, and has been proactively meeting with the bureau to highlights the benefits and high satisfaction level of overdraft services for credit union members.
- The U.S. Department of Labor’s overtime pay proposal, which would double the salary threshold for overtime eligibility and sweep in nearly 5 million more people. CUNA has concerns that the proposal will unfairly impact credit unions in general but particularly small credit unions.
CUNA’s list also includes cybersecurity issues, the CFPB proposed rule for payday and other small dollar lending, a potential CFPB debt collection proposed rule, NCUA examination issues, the NCUA’s interest on lawyer trust accounts rule, the NCUA’s risk-based capital rule, and regulatory relief from overly burdensome rules finalized last year such as the Truth in Lending Act-Real Estate Settlement Procedures Act, the Home Mortgage Disclosure Act, and the Telephone Consumer Protection Act.