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Important Regulatory Review Comments Due in August
Tuesday, August 2, 2016 6:50 AM

A number of important credit union rulemakings have comment deadlines this month. Significant proposals from the National Credit Union Administration and the Consumer Financial Protection Bureau are in this month’s comment deadlines.

On Aug. 22, comments are due on CFPB’s proposal on arbitration agreements, which would severely restrict the use of pre-dispute arbitration clauses that are included in many agreements for consumer financial products.

Credit unions have different dispute resolution dynamics because of their structure; they have also expressed concerns about frivolous class action litigation as a result of new regulations with technical requirements, which has increased their interest in preserving arbitration as an option. Even if you do not use arbitration language in your contracts today, you may want to in the future.

Below, please find other proposals with comments due in August.

  • Aug. 8: NCUA 2016 regulatory review. NCUA continually reviews its regulations to determine whether they should be updated, clarified, simplified, or eliminated. This year’s regulations include credit union service organizations, member business loans, Central Liquidity Facility, requirements for insurance and more;
     
  • Aug. 10: CFPB amendments to annual privacy notice requirements under the Gramm-Leach-Bliley Act. The Fixing America’s Surface Transportation Act mandates CFPB eliminate the unnecessary and outdated compliance burden of providing annual privacy notices if certain conditions are satisfied. CUNA submitted its comment letter Monday; and
     
  • Aug. 15: NCUA Call Report Modernization. The deadline to provide feedback to NCUA regarding the structure of call reports has been extended to August 15.
     
  • Aug. 22: NCUA technical changes to the Community Development Revolving Loan Fund. The fund supports credit unions serving predominantly low-income members, as well as low-income credit unions in emergencies. The proposal is designed to improve transparency, organization and ease of use of the fund. 

Be sure to copy Cornerstone SVP Regulatory Compliance Suzanne Yashewski on your comment letters to the regulators. For assistance in drafting your comment letter, contact Suzanne at 512-853-8516 or syashewski@cornerstoneleague.coop.