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Removing Barriers Blog

CUNA Offers Suggestions in Letter to Senate to Improve SBRFEA Process

CUNA sent a letter to the Senate Homeland Security and Government Oversight Committee with suggestions for improving the SBREFA process, prior to a hearing entitled, “Improving Small Business Input on Federal Regulations: Ideas for Congress and a New Administration.” 

In our letter, we urge Congress to consider feedback from a number of credit unions that participated on SBREFA panels that they felt that final rules did not include enough changes and/or exemptions to limit impact on small credit unions. We noted that as a result, small credit unions have had the most difficulty complying with new mortgage rules even after participating in SBREFA.  

Our letter also encourages Congress to continue to analyze whether CFPB final rules properly address credit union and other small financial institution concerns. CUNA also discusses in the letter why more transparency, longer time frames for SBREFA, and fewer burdens on small financial institutions participating could lead to an improved SBREFA process. 

Specific to the CFPB’s proposed rule for payday and small dollar loans, the letter encourages Congress to consider that not only did the SBA Office of Advocacy express concerns with how this proposed rule will harm credit unions members, but so did the NCUA, credit unions’ primary regulator that has overseen them for more than 40 years. In the letter, we encourage Congress to address these important concerns of other regulators with the CFPB. We also urge Congress to consider whether the CFPB should more effectively consult with primary prudential financial regulators even before beginning the SBREFA process.