Removing Barriers Blog

CUNA Comments on the Bureau's RFI on Enforcement Practices
Posted May 14, 2018 by Chandler Schuette

CUNA commented on the Bureau of Consumer Financial Protection's (BCFP) request for information on enforcement practices.  In the letter, CUNA urged the Bureau to delegate to the NCUA primary examination and enforcement of consumer protection laws for credit unions with more than $10 billion in assets.

“CUNA supports [transferring examination and enforcement authority] as it will enable the bureau to fully focus its examination and enforcement efforts on Wall Street banks and other abusers of consumers, while ensuring credit unions continue to be adequately supervised by the federal agency most proficient with its structure and operation,” the letter reads.

CUNA added that, if the Bureau retains examination and enforcement over credit unions with over $10 billion in assets, it must work together with the NCUA as a partner throughout the examination and enforcement process.

Other highlights of the letter include:

  • The Bureau must not impose enforcement actions that are not supported by prescriptive laws, regulations, or guidance under its jurisdiction.
  • If the Bureau continues primary examination and enforcement over the largest credit unions, then its processes must be more transparent and directed at resolving any violations, with enforcement actions serving as a last resort.
  • The Bureau should establish for the financial services industry a matrix for how it determines civil money penalties. This matrix should be published for notice and comment.