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Nussle Op-Ed: Anniversary of Dodd-Frankā€”A Big Dud
Monday, July 25, 2016 6:45 AM

By Jim Nussle, President/CEO of Credit Union National Association

In the days and weeks leading up to the effective date of the Truth in Lending Act-Real Estate Settlement Procedures Act integrated disclosures (TRID) rule, the offices of the Credit Union National Association’s compliance officials in Madison and Washington, DC, sounded like a radio station in the midst of a major giveaway. The phones never stopped ringing.

One CUNA compliance expert recalled that every day, all day, credit unions called in or emailed with questions about implementation of the rule, with the questions becoming increasingly complex the deeper credit unions dove into the regulation.

On many occasions, it took compliance staff hours to pore through TRID to respond, likely after substantial time invested by the credit union to understand the rule.

Six years following the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act, signed into law to the day today, July 21, 2010, the calls and emails have diminished, but not stopped.  

And they won’t, because this is a credit union’s new reality.

Credit Unions 'Swamped'
A law passed specifically to stomp out the irresponsible behavior of the big banks has swamped credit unions with overregulation.

No matter the intentions, which were clear as Congress embroidered the words “Wall Street Reform” into the name of the bill, the consequences have been incredibly problematic for credit unions and, more importantly, to their consumer-friendly financial products and services. 

More than a quarter of all credit union employees now solely work on compliance, a number that rises to nearly 50 percent for our smaller members, and as an industry, our compliance costs rose nearly 100 percent between 2010 and 2016, according to our cost-of-regulatory-burden study.

These costs are shouldered directly by credit union members, as credit unions often tell us they would hike interest rates on deposits and slim down rates on loans if it weren’t for the additional compliance costs. Washington certainly did not intentionally want consumers, who had nothing to do with the Great Recession, paying for the mistakes made by those who led to our economy’s demise.

CUNA bends over backwards for our member credit unions to ensure they can meet this mounting challenge. Collaborating with our League partners, we’re developing newer and more effective ways to help credit unions stay in compliance.

We offer the CUNA Compliance Community, which houses innumerable downloadable resources for members, while also offering a space to bounce questions off of peers working the front lines of regulatory burden. Members can have any compliance question answered by emailing And we host and coordinate a loaded calendar full of webinars, eSchools, in-person events, and training.

'It Will Only Get Worse'
But these are not solutions to the real problem. The pace and complexity of regulations that credit unions are required to grapple with is unsustainable. If we stay on this course, credit unions will be forced to raise costs or cut further back on the services they can provide. And it will only get worse.

In fact, it’s already happening. The phone calls again are ramping up.  

The implementation date for the Home Mortgage Disclosure Act looms and, once again, credit unions, baffled and overwhelmed by the regulations that continue to pile up on their desks, are turning to experts to sift through the complexity.

Credit unions were established to promote thrift, to support their communities, and to serve their members by ensuring security in their financial lives.

Credit unions were not established to fill out the government’s paperwork. Yet, increasingly, despite playing absolutely no part in the financial crisis, it seems that’s all they have time to do.