Removing Barriers Blog

Follow-Up Letter to Meeting with CFPB Director Cordray
Posted October 05, 2015 by CUNA Advocacy

Today we sent a letter to CFPB Director Richard Cordray, thanking him for meeting with CUNA staff and credit union Chief Executive Officers to discuss consumer financial regulatory issues facing the credit union industry.

In particular, we appreciated Director Cordray's acknowledgement that institutions will need more time to comply with the new TRID forms, and for providing a written statement granting institutions a transition period of enforcement and examination relief for good-faith compliance. We are hoping the CFPB and NCUA will be sensitive to the compliance efforts of credit unions so implementation can progress smoothly.

The letter also expressed concerns regarding the new omnibus declaratory ruling and order (Order) from the Federal Communications Commission (FCC) that is affecting the ability of credit unions to communicate important information. This Order is actually harmful to consumers who may not be aware of important account information, such as late payments and potential delinquencies to their accounts that could negatively impact their credit scores. We urged CFPB to ensure the FCC’s Order does not impede credit unions’ ability to provide the necessary consumer protections endorsed and required by the Bureau.

Finally, we stressed that the CFPB should focus its rulemaking and enforcement actions on the irresponsible actors in the industry, so the good actors, such as credit unions, are not negatively impacted by additional burdens. We believe focused rulemaking is particularly achievable in the CFPB’s future rulemakings on small-dollar loans, debt collection, and overdraft protection, where credit unions have not been responsible for the consumer harm caused. We closed the thank-you letter by stressing that the mission of credit unions and the CFPB are aligned, and that we look forward to opportunities to work together to further our shared objectives. The full letter is available here.