Removing Barriers Blog

COVID-19: CUNA writes to President re: statutory and regulatory accommodations
Posted March 18, 2020 by CUNA Advocacy

Earlier this week, CUNA wrote to the President about the statutory and regulatory accommodations needed to ensure credit unions can continue to meet the financial services needs of their members impacted by the coronavirus (COVID-19).

“Credit unions are open for business and serving their members. Their top priority right now is keeping their members, volunteers and employees safe and healthy, and remaining in a position to serve members and the community during and after the crisis,” the letter reads. “More than 2,100 credit unions, serving nearly 46 million members, have a primary field of membership that includes schools, military, health care, police, fire, transportation, utilities and government employees. These credit unions and others are serving members who are on the front lines of helping to keep others safe during this crisis. Of course, since this crisis will impact everyone, every credit union will be impacted.”

Given the severity of the crisis and the need for quick action by the administration, federal agencies and Congress, CUNA asked the administration to support the following requests:

  • NCUA and the Consumer Financial Protection Bureau (CFPB) should
    • Suspend all pending rulemakings - and not propose additional rulemakings - that will not provide regulatory relief for financial institutions at this time.
    • Extend the effective dates for recently finalized regulations until 2021, unless the regulation provides additional flexibility or relief to financial institutions. 
    • Suspend all routine onsite examinations for at least the next 120 days.
    • Not penalize credit unions that work with their members to weather the crisis through the implementation of short-term emergency loan programs, skip-a-payment programs, loan modifications, fee waivers and other accommodations.
  • NCUA should issue guidance to federal credit unions allowing membership meetings and board meetings to be conducted virtually;
  • The administration should direct the Financial Accounting Standards Board (FASB) to suspend implementation of its current expected credit loss (CECL) standard for at least one year, until January 2024;
  • Congress should increase appropriations for the Community Development Revolving Loan Fund (CDRLF) and the Community Development Financial Institution Fund (CDFIF);
  • Congress should enact legislation exempting credit union business loans made during federally declared disasters and emergencies from the credit union member business lending cap;
  • Congress should enact legislation to exempt government-guaranteed loans made through programs at the Small Business Administration, Department of Agriculture and other agencies from the credit union member business lending cap;
  • CFPB should allow consumers to waive the rigid requirements related to the specific timing of disclosures (e.g. the three-day closing disclosure requirement) under the TILA-RESPA Integrated Disclosure (TRID) rule; and
  • CFPB should expedite its amendment to the Remittance Rule increasing the “normal course of business” safe harbor and make an accommodation for transfers sent to individuals affected by the growing pandemic.