WASHINGTON (3/8/12)--The Credit Union National Association (CUNA) in a comment letter urged the Consumer Financial Protection Bureau (CFPB) to minimize any and all new regulatory requirements for credit unions, and said the agency's regulatory streamlining review should result in "lasting and meaningful regulatory relief" for credit unions "that already serve consumers and small businesses well."
The CFPB last year announced it would accept public comment on how best to streamline the 14 rules that it inherited from the National Credit Union Administration, the Federal Reserve, the Department of Housing and Urban Development, the Federal Deposit Insurance Corporation, the Federal Trade Commission, the Office of Comptroller of the Currency and the Office of Thrift Supervision.
The revisions are meant "to make it easier for banks, credit unions and others to follow the rules" and ensure that regulations work better for consumers and the firms that serve them.
CUNA's Deputy General Counsel Mary Dunn urged the bureau not to contribute to credit union's regulatory burdens and instead, to help minimize them.
"The number one regulatory advocacy priority for CUNA is to minimize the number and complexity of costly regulatory requirements that divert credit unions' time and economic resources from member service," Dunn wrote. CUNA also urged the agency to consider how it can exempt credit unions from future regulatory requirements.
"Credit unions simply do not need, and will have increasing difficulties assimilating, additional regulatory burdens if they are to fulfill their purpose of responding to their members' financial needs," the letter added.
Dunn said that CUNA does not think that credit unions are a direct target of CFPB regulatory efforts. But, "there is also a concern that credit unions may suffer collateral damage as a result of the agency's efforts to direct rules toward others," she added.
The CUNA comment letter cited the recent remittance final rule and concerns about the CFPB's announced intention to investigate overdraft protection programs. "We urge the agency to approach the review of overdraft protection with reasonableness and allow financial institutions to structure overdraft programs and other check payment accommodations with flexibility, consistent with legal requirements and fairness," Dunn wrote.
In terms of regulatory relief areas, she urged the agency to focus first on the mortgage lending process to improve it for consumers and lenders alike. If the agency decides to review rules on an individual basis, the Truth-in-Lending and Real Estate Settlement Procedure Acts "should be at the top of the list for review and improvements," CUNA said.
The CFPB plans to consider simplifying some regulations, standardizing some common terms across regulations, updating outdated or unneeded regulations, and removing unnecessary restrictions on consumer choice or business innovation.
CUNA said the bureau should conduct similar regulatory streamlining reviews on an annual basis, publishing a list of rules it plans to review before the start of each year. CUNA suggested the list of rules be open for public comment for 120 days.
The regulatory transfers were mandated by the Dodd Frank Act. CUNA has commented on almost all rules that have been transferred to the bureau that have been published for comment and that affect credit unions.
For the full CUNA comment letter, use the resource link.