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
Credit Losses for Financial Instruments Proposal 02/05/2016 FASB Closed
Field of Membership Comment Letter 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
Regulatory Impact Assessment & Initial Regulatory Flexibility Analysis re FinCEN’s CDD Proposal 01/22/2016 FinCEN Closed
Joint Trades letter on FHFA proposed collection of information relating to the National Survey of Existing Mortgage Borrowers (“NSEMB”) 01/11/2016 FHFA Closed
Letter on OMB’s review of CFPB HMDA information collection 01/09/2016 CFPB Closed
NCUA Bank Notes Rule 11/23/2015 NCUA Closed
Letter to CFPB on SBREFA Panel for Arbitration 11/13/2015 CFPB Closed
Letter to NCUA on 2016 Budget Concerns 11/12/2015 NCUA Closed
Request to Develop Survey on POS/ATM Overdraft Disclosure 11/02/2015 CFPB Closed
OMB Request for Web-Based Quantitative Testing of Point of Sale/ATM Overdraft Disclosure Forms 11/02/2015 CFPB Closed
FinCEN Proposes New AML/SAR Requirements for Investment Advisers 10/30/2015 FinCEN Closed
Comment Letter on OMB review of NCUA data 10/26/2015 NCUA Closed
Follow Up Letter to CFPB ODP Meeting 10/22/2015 CFPB Closed
ODFI Registration of Third Party Senders with NACHA 10/09/2015 NACHA Closed
Post Meeting Letter to CFPB Director Richard Cordray 10/05/2015 CFPB Closed
Treasury RFI re Online Marketplace Lending 09/29/2015 Other Closed
Letter to NCUA on RBC, MBL, and Examinations 09/23/2015 NCUA Closed
Letter to NCUA on EGRPRA Review 09/22/2015 NCUA 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