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the last two years or so, we in the CUNA/League system have been talking a lot
about “360 Degree Advocacy,” this notion that if public policy issues facing
credit unions are addressed from all angles, and resources are brought to bear
strategically and deliberately, the likelihood of a successful outcome is
increased significantly. Last week, we
saw what 360 Degree Advocacy can do on two key issues – CFPB’s small dollar
loan Proposal and NCUA’s supervisory improvement process. To be certain, this was not the first time
this approach produced positive results, but the progress we’ve made on these
issues would not have been achieved if we had approached them “the old way.”
No less than eighteen
months ago, NCUA was a solid “no” on our request that they look at extending
examination cycles for healthy credit unions and bringing fairness and
modernization to the supervisory process.
But working together – CUNA, Leagues and credit unions – we took our
case to both the agency and the Congress.
When NCUA asked credit unions for their ideas, they delivered. Last
week, the Agency announced its latest steps toward extended exam cycles for
healthy credit unions and we believe they are well on their way to making the
supervisory process more efficient. It’s
not happening overnight and we’re a long way from the end, but we’re also a
long way from “no” thanks to 360 Degree Advocacy.
The CFPB’s payday
proposal is a horse of a different color.
It’s harder to see the positive impact because the proposal has not been
finalized. Nevertheless, the conclusion
of the comment period is an appropriate time to reflect on the impact we have
made so far.
When the HMDA rule
was finalized, we saw that despite our best efforts – the best efforts of the
entire financial services industry – the CFPB had not listened to our
concerns. We needed a change in
strategy; we knew it was time to be more aggressive.
We took our message
to the press, publishing op-eds to raise awareness of our concerns. Together, we organized 329 members of the
House – bipartisan majorities of both parties – to send a letter to the CFPB
urging them to use their exemption authority.
We didn’t back down when the Director said “No.” But, when the proposal came out in May, lo
and behold, they used the authority…just not exactly how we would like them
to. So, we pressed on. CUNA, Leagues and credit unions got 70
members of the Senate to write the CFPB with an even stronger message. Dozens of Leagues and hundreds of credit
unions met with CFPB officials over the summer and into the fall as part of the
CUNA/League system’s Hike the Hill program – many of these meetings were
captured as part of the CFPB’s ex parte discussion process. Thousands of credit union employees wrote the
CFPB with their stories of how they help members with small dollar loans. Many credit unions filed their own comment
letters with the Bureau. We engaged NCUA
and the Small Business Administration Office of Advocacy to make sure they
understood our concerns as well.
It’s hard to say how
the final rule will come out, but thanks to the combined and coordinated
efforts of CUNA, Leagues and credit unions, nearly 400 Members of Congress, the
SBA Office of Advocacy and the NCUA have articulated our concerns and in some
cases our proposed solutions. We have submitted one of the more comprehensive
comment letters filed on this proposal, and we have a legal comment letter that
outlines how the CFPB has exceeded its authority. Our case is strong and we will press on.
The point that I am trying
to make here is that none of this gets done if we don’t work together. 360 Degree Advocacy is more a catch
phrase: it's an advocacy strategy that is making a difference in the challenging public policy environment we face. And working together,
approaching issues from all sides, we will continue to make progress for credit
unions and their members.
-- Ryan Donovan
Champion for the Credit Union Movement
Credit Union National Association is the most influential financial services trade association and the only national association that advocates on behalf of all of America's credit unions. We work tirelessly to protect your best interests in Washington and all 50 states. We fuel your professional growth at every level and champion the credit union story at every turn.
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