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This week, CUNA attorneys joined nearly 150 lawyers in
Orlando, Florida to discuss issues facing the credit union industry. Regulators
from both the Consumer Financial Protection Bureau (CFPB) and the National
Credit Union Administration (NCUA) also participated in the event.
Corey Stone, CFPB assistant director of Credit Information
and Deposits Markets, joined Senior Directors of Advocacy and Counsel Luke
Martone and Leah Dempsey in a presentation about Overdraft Protection and the
CFPB’s proposals under consideration for Payday and Small-Dollar loans. During
the presentation, Martone urged the CFPB to consider consumer education, rather
than regulation of the Overdraft service particularly in light of the high
level of satisfaction for using it as shown by the low number of complaints.
In the discussion concerning the Payday and Small-Dollar
proposals under consideration by the CFPB, Dempsey noted that while CUNA
strongly supports many of the consumer protections found in the proposals under
consideration, particularly those targeting bad actors, we are very concerned
about any impact this rule could have on the NCUA PAL program and other similar
services offered by credit unions. She urged the CFPB to consider how all of
its rulemakings together will impact the availability of credit and funds for
credit union members.
Senior Director of Advocacy and Counsel Lance Noggle
participated in a panel with the NCUA’s Associate General Counsel Frank
Kressman, Staff Attorney Justin Anderson, and Staff Attorney Regina Metz.
During the presentation the NCUA representatives discussed Member Business
lending, Field of Membership, and the Office of Consumer Protection.
During a separate presentation with Dempsey, CUNA’s Deputy
Chief Advocacy Officer and Senior Counsel Elizabeth Eurgubian provided an
overview of the issues and pending rulemakings from the CFPB that are impacting
credit unions. Eurgubian also provided an outline of how CUNA’s new advocacy structure
which includes collaboration of regulatory, legislative, communications, and
compliance functions is necessary for the new regulatory environment credit
unions are facing. During the presentation, Eurgubian also discussed recent
final rules such as TRID and HMDA, and noted that CUNA’s work is not done when
a final rule comes out, particularly when there is still a need to advocate for
changes to the final rule. The presentation also addressed pending rulemakings
such as the Payday, Small-Dollar proposals under consideration, the impending Debt
Collection proposed rule, the impending Prepaid final rule, pending Overdraft
rules, and the Arbitration SBREFA panel.
Additionally, Senior Director of Advocacy and Counsel Andy
Price and Chief Compliance Officer Jared Ihrig provided an overview of Hot
Regulatory and Compliance issues for credit unions. During this panel, Price
discussed CUNA’s work in response to the recent FCC TCPA Omnibus Order, and
outlined some compliance concerns credit unions may be facing as a result of
this Order. Ihrig also discussed the recent final rule concerning the Military
Lending Act from the Department of Defense. Additionally, he outlined concerns
with recent class-actions and enforcement actions impacting the industry.
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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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