Regulatory Priorities

Regulatory advocacy is crucial to credit unions' strength, growth, and success. After Congress or a state legislature enacts laws, federal or state administrative agencies develop the details for implementing the laws and outlining what credit unions must do to comply.

This rulemaking process follows its own set of rules, including mandatory public notice of any new regulations or proposed changes to existing regulations. The process mandates that those impacted have an opportunity to provide feedback to the issuing agency. The agency must then consider and address all comments received prior to adopting a regulation. In many instances, an agency may amend or even withdraw a proposal based on public commentary.

Cornerstone diligently monitors rulemaking by regulatory authorities, and we advocate for our members’ priorities by submitting comment letters on their behalf. We coordinate our efforts with our system partner, America's Credit Unions, consult with our regulatory engagement committee, and seek feedback from member credit unions. To best represent credit union interests, Cornerstone needs to hear from you about your concerns or suggestions regarding regulatory matters, so please let us know how you feel.

In addition to Cornerstone’s efforts, it’s important for credit unions to comment directly to regulators on matters of concern. If you submit a comment letter directly to a regulator, please copy Cornerstone at syashewski@cornerstoneleague.coop.

Cornerstone's comment letters on current and historical issues can be accessed below. These letters were delivered to regulators on your behalf. They also serve as a model for your own comment letters to regulators.

Comment letters do not need to be lengthy or detailed but should specify the impact of the issue on your operations, including quantifiable costs or increased labor needs, which are particularly helpful.

Following are Cornerstone’s current regulatory priorities.

Current Regulatory Priorities

Debit Interchange Fees and Routing,

Federal Reserve Regulation II

The Board of Governors of the Federal Reserve System has proposed to lower the debit interchange cap for credit unions with over $10 billion in assets. The proposal will negatively impact credit unions and benefit large retailers.

See comment letters to the Fed from Cornerstone League and America’s Credit Unions. A final decision is expected in January 2025.

 

Overdraft/NSF on Declined Transactions, CFPB

The CFPB has classified overdraft and NSF fees on declined transactions as “junk fees.” It has proposed stringent limits on ODP fees for credit unions with $10 billion in assets and would prohibit NSF fees on transactions that are declined instantaneously or near-instantaneously by any credit union regardless of size. The final rule on NSF is expected in October 2024 and on ODP in January 2025.

Cornerstone League submitted comment letters to the CFPB on ODP and NSF. See letters by ACU on ODP and NSF.

 

Credit Card Late Fees, CFPB

The CFPB’s final rule to reduce credit card late fees was originally scheduled to take effect on May 14, 2024. However, a federal judge paused the rule limiting late fees to $8 and eliminated annual inflation adjustments.

See Cornerstone League’s comment letter.
comment call

Comment Calls

Learn more about comment calls and how to write them.

Comments

Cornerstone Comment Letters

View the letters that Cornerstone has issued on your behalf.

Meeting Summaries

Regulatory Meeting Summaries

Read a summary of the latest regulatory meetings.

View America's Credit Unions' comment calls and letters on its website.

Questions?

Contact Suzanne Yashewski at 512-853-8516.