Removing Barriers Blog

CUNA Provides CFPB with Detailed Summary of Changes to Better Protect Credit Union Members

CUNA sent CFPB Director Cordray a detailed list of suggestions, accompanied by a letter, highlighting the ways the CFPB’s rulemaking have adversely affected the way credit unions operate and serve their members.  In addition to outlining the issues, CUNA also included recommendations on how the CFPB should improve its regulations and rulemakings to provide much needed relief to credit unions and their members.  

The letter outlines: 

  • The negative effects CFPB regulations have had on credit union operations, their products and services, and their members even for rules the CFPB claims to have accommodated credit unions in; 

  • The costs borne by credit unions as a result of CFPB regulations—not including the additional costs that will be incurred as a result of the Home Mortgage Disclosure Act (HMDA) and Truth in Lending Act/Real Estate Settlement Procedures Act Integrated Disclosure (TRID) requirements; and 

  • The failure of the CFPB both to use its legal authority to exempt credit unions from certain regulations and to adequately account for the size, complexity, structure, or mission of all credit unions. 

The letter also includes detailed recommendations for how the CFPB can improve its work on: 

  • HMDA; 

  • Mortgage origination rules; 

  • Mortgage servicing regulations; 

  • Remittances 

  • The Fair Debt Collection Practice Act; 

  • Indirect lending; 

  • Prepaid cards; 

  • Payday and small-dollar loans; 

  • Unfair, deceptive, or abusive acts or practices; 

  • Voluntary products; 

  • Arbitration; 

  • Small business lending; and 

  • Access to financial records. 

The current one-size-fits-all regulatory scheme employed by the CFPB does not work for credit unions and other community financial institutions, but rather favors the largest banks who have access to unlimited compliance resources.  CUNA will continue to push for common-sense regulations and urge the Bureau to use their exemption authority for credit unions.