Removing Barriers Blog

CUNA Sends Comments to Treasury Outlining Regulatory Burdens
Posted July 31, 2017 by CUNA Advocacy

Today, CUNA Senior Director of Advocacy and Counsel Leah Dempsey, sent a letter to the U.S. Department of the Treasury (Treasury) outlining areas where regulatory burdens are harming the ability of credit unions to serve their members. 

The Treasury’s inquiry into this issue is in response to Executive Order 13771, Reducing Regulation and Controlling Regulatory Costs, which directs agencies to eliminate two regulations for each new regulation issued and to limit costs for this fiscal year to zero and Executive Order 13777, Enforcing the Regulatory Reform Agenda, which requires agencies to convene a regulatory reform task force to assist in the implementation of Executive Order 13771. 

CUNA in its letter expressed concerned with the overall cost of compliance for credit unions from CFPB rules. It stated that more appropriate tailoring of rules, and providing credit union exemptions when warranted in areas where credit unions have no pattern of harm to consumers, would create a better operating environment for consumers. In the letter to treasury, we provided specific changes to CFPB rules and policymaking that would provide credit unions with greater ability to provide their safe and affordable products and services. 

In the letter, CUNA also outlines a number of suggestions for the Treasury to find a better balance between BSA/AML requirements and costs to small financial institutions. The letter notes that credit unions are deeply committed to the fight against financial crime, but it is important to recognize that credit unions are not law enforcement agents and have certain fundamental limitations. It provides detailed suggestions on how costs can be reduced without limiting credit unions efforts to prevent criminal activity. 

The letter also noted that the federal government should strongly support Community Development Credit Unions and the NCUA’s Community Development Revolving Loan Fund. It argues that these programs are important for American consumers, including many who are financially distressed and underserved. 

Additionally, the letter provides suggestions for Housing Finance reform, the Military Lending Act, and the Telephone Consumer Protection Act. 

Earlier this year, credit union representatives and CUNA staff met with Treasury to outline areas where regulatory burdens are harming the ability of credit unions to serve their members. We will continue to urge the Treasury to engage with other regulators to improve the operating environment for credit unions.