Removing Barriers Blog

CUNA's Compliance Team Highlights Key Provisions & Effective Dates for S. 2155
Posted May 31, 2018 by CUNA Advocacy

Last week’s passage of S. 2155 was a huge victory for credit unions!  This landmark regulatory relief bill benefits credit unions in a variety of ways, from increasing the MBL cap by removing 1-to-4 family non-owner occupied residential property from the cap, to rolling back the onerous HMDA data points imposed by Dodd-Frank.  Here at CUNA Compliance, the questions about S. 2155 have been rolling in at a steady pace, so we have compiled a summary chart of the provisions most likely to affect credit unions, and when they become effective.  Note that these summaries are provided by the Senate Banking Committee and the full version is available here.

Note that the effective date field is blank for the majority of the provisions.  This means that the Act was silent and did not specify an effective date for that particular provision.   This usually means that the provision is effective upon the date of enactment (which was 5/24/2018).  However, from a compliance standpoint it is not always that simple, as the agency regulation could not contain conflicting information that will need to be revised.  We hope that the agencies will work with the industry in facilitating compliance with the Act as quickly as possible and provide us with guidance in the interim.  Stay tuned for future updates from CUNA as well will be posting a series of blogs that will dive deeper into the sections of the Act that will be particularly important for Compliance folks.   In the meantime, feel free to reach out to CUNA Compliance with any questions you may have.