Removing Barriers Blog

CUNA Subcommittees Meet with Senior Regulatory Officials
Posted October 16, 2015 by CUNA Advocacy

This week, members of CUNA’s Consumer Protection and Examination/Supervision Subcommittees met with top federal regulators in Washington DC. The first meeting occurred with NCUA Chair Debbie Matz directly following the agency’s finalization of its Risk-Based Capital Rule. The second meeting occurred with senior officials at the CFPB, including Kelly Cochran, Corey Stone, Mark Morelli and others.

The meeting with NCUA featured a similar discussion of overdraft policies and Military Lending Act compliance. In meetings with both Matz and Larry Fazio, members discussed:

  • The Telephone Consumer Protection Act, the problems it could create for credit unions and how we are very unsatisfied with the scope of the Federal Communications Commission exemption;
  • Recent and upcoming changes to supplemental capital, exam efficiency, Member Business Lending, and Field of Membership
  • Consumer complaint databases at both the NCUA and CFPB; and
  • Compliance and enforcement of the Truth in Lending Act-Real Estate Settlement Procedures Act integrated disclosures (TRID) rule. We asked the NCUA to work closely with the CFPB to address the regulatory burden of the rule and to provide more exemptions to credit unions. 

At the CFPB meeting that occurred the next day, participants noted that they were frustrated with the finalized HMDA rule that came down yesterday, and felt that credit union input was not adequately considered.

On overdraft issues, Bureau staff indicated that they are trying to learn about small institutions and credit union overdraft services through data collected from service providers. Participants urged the CFPB to learn more from credit union members directly about their appreciation and use of overdraft/courtesy pay services. They also outlined how credit union members use these services, and why they are sometimes their best option for funds. Senior staffer Corey Stone then discussed some of the findings of previous CFPB overdraft related studies. 

This meeting also featured a discussion of short-term, small dollar loans, on which the bureau issued a proposal in March.  Meeting participants urged the CFPB to leave the NCUA Payday Loan Alternative program in place without additional compliance burdens. We recently conducted a survey to determine how these proposals will impact credit unions, and stressed that our survey findings indicate that credit unions are unable to take on any additional regulatory burdens on top of the PAL program, without severely diminishing the viability of short term lending. We also outlined why the recent DOD Military Lending rule changes are problematic for credit unions offering PAL loans.