Comment Letters

Your comments are put into action in these letters sent by CUNA in response to regulatory proposals.

Listed below are all pending regulations for which CUNA has published a Comment Letter, regardless of current status. The listed date is the most relevant date for the status that the regulation is in: it could be the CUNA or agency due date, a Comment Letter publish date, or a Final Rule effective date, depending on whether the regulation is currently in the Call, Letter, or Analysis status.

Pending Changes can be sorted by any column in the green bar (Issue, Date, Agency, or Current Status), ascending or descending. For Comment Letters, a current status of "Closed" indicates the Letter has been sent to the agency. You can also use the "Archive" link at lower left for older items.

Please note: we now provide short summaries for significant Final Rules, which can be found on the same page as the comment letters. Our more detailed Final Rule Analyses are now available on the Compliance page

Issue Date Agency Current Status
NCUA Strategic Plan 2017-2021 04/04/2016 NCUA Open
Ohio League Letter to Richard Cordray on Credit Union Small Dollar Loans 05/02/2016 CFPB Closed
Letter on NCUA's Operating Fee Schedule 04/26/2016 NCUA Closed
Comment Regarding NCUA Overhead Transfer Rate Methodology 04/26/2016 NCUA Closed
Comment Letter on CFPB Interim Final Rule Defining Rural Areas under FAST Act 04/21/2016 CFPB Closed
CUNA and Joint Trades Amicus Brief on City of Miami v. Bank of America 04/04/2016 Other Closed
Changes to the BSA Currency Transaction Report 03/29/2016 FinCEN Closed
Letter to NCUA on EGRPRA Part 4 03/23/2016 NCUA Closed
Letter to CFPB Director Cordray Following Spring 2016 CFPB House oversight hearing 03/22/2016 CFPB Closed
Credit Losses for Financial Instruments Proposal 03/17/2016 FASB Closed
Letter to FHFA on Fannie and Freddie’s Duty to Serve 03/16/2016 FHFA Closed
Request for Information Regarding HDMA Resubmission Guidelines 03/11/2016 CFPB Closed
Letter to the Florida Bar Board of Governors urging them to allow credit unions to accept IOLTA accounts 02/19/2016 Other Closed
CFPB Regarding Rural Designation Process in FAST Act 02/11/2016 CFPB Closed
The Holder Rule 02/10/2016 Other Closed
Letter to CFPB Directory Cordray on Exemption Authority 02/10/2016 CFPB Closed
NIST RFI: Updates to the Cybersecurity Framework 02/09/2016 Other Closed
NCUA Field of Membership Proposal 02/03/2016 NCUA Closed
Letter to NCUA on DOL Overtime and Fiduciary Rules 01/27/2016 NCUA Closed
Military Lending Act Proposal 01/26/2016 Other Closed

Status Key

  • OPEN = CUNA seeking input to prepare comment to agency
  • CLOSED = CUNA comment filed, agency comment period closed
  • FINAL = Agency has issued final ruling