WASHINGTON (7/21/11)--With the one-year anniversary of Dodd-Frank Wall Street Reform Act enactment coming today, the Credit Union National Association notes that its priority over the past year, and into the future, remains limiting the impact of related regulations on credit unions. A number of Dodd-Frank provisions also become effective today. The largest Dodd-Frank issue for credit unions, and CUNA, is the Federal Reserve’s debit interchange fee cap. While credit union input ultimately helped lessen the impact of the Fed’s final rule for both larger and smaller institutions by altering the rule, CUNA continues to encourage Congress to keep a watchful eye on the implementation process. CUNA is pressing the networks to ensure a two-tiered system is provided that will allow small issuers such as most credit unions to obtain more debit fee income than will be permitted for large issuers under the Fed’s final rule. CUNA is also planning to work with the Fed as it monitors the impact of the interchange rule on credit unions and other institutions. Title XIV of the Act, which addresses mortgage regulations, is another point of emphasis for credit unions and CUNA. Portions of this title that cover mortgage servicing and some mortgage appraisal activities are currently effective. Many other mortgage-related changes, including changes to disclosure requirements, underwriting standards, and new high-cost mortgage standards are set to become effective in the future. These rules have staggered effective dates. More pressing for credit unions are portions of the Dodd-Frank Act that come into effect today. As of today:
* The limit on next-day availability for deposited checks will increase to $200. The previous limit was $100. * The Truth in Lending Act and Consumer Leasing Act will also apply to consumer credit transactions and consumer leases of up to $50,000. This $50,000 cap will increase to $50,800 on January 1, and can be adjusted further in the future. The previous cap was $25,000.
While the official compliance date for credit score notice changes is listed as July 21, the changes were not published until July 15, so by law they cannot become effective until August 15. Still, CUNA has recommended that credit unions begin complying with these changes, which require additional information to be provided on risk based pricing and adverse action notices that are released to credit union members. For more on these changes, use the resource link to access CUNA’s Compliance Blog
. The Consumer Financial Protection Bureau also officially begins its work today. The agency begins its work without a leader, and amid congressional threats to its future funding. Still, it is intact, and will take on oversight of the Equal Credit Opportunity Act and the Fair Credit Reporting Act, as well as regulations addressing electronic fund transfers, mortgage originator registration, and mortgage assistance relief services, today. Authority over 47 separate financial rules is being transferred to the CFPB from the National Credit Union Administration, the Federal Reserve, the Federal Deposit Insurance Corp., the Office of the Comptroller of the Currency, the Office of Thrift Supervision, the Federal Trade Commission, and the U.S. Department of Housing and Urban Development. CFPB representatives have said that the agency is "committed to remaining attentive" to the concerns of credit unions and will work to address the concerns of credit unions and other small issuers as it develops and amends regulations. CUNA earlier this month called on the CFPB to consider the differences between member-owned financial cooperatives such as credit unions and for-profit banks that put the interests of their shareholders first as it continues with its work.