Removing Barriers Blog

360 Degree Advocacy On Full Display in Payday, Exam Efforts
Posted October 11, 2016 by CUNA Advocacy

For 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