Removing Barriers Blog

Letter sent ahead of HFSC hearing with Treasury & Fed
Posted July 01, 2020 by CUNA Advocacy

Yesterday, CUNA wrote to Chairwoman Waters (D-CA) and Ranking Member McHenry (R-NC) expressing views ahead of the House Financial Services Committee hearing on the Oversight of the Treasury Department's and Federal Reserve's Pandemic Response. The pandemic response from the Treasury and Federal Reserve has helped stabilize the economy, but additional actions could continue to help individuals and businesses.

CUNA strongly supports the Fed’s action to remove the account transfer limit under Regulation D, and wrote to the Fed earlier this week requesting the removal be made permanent.

The letter also notes credit unions’ support of the Paycheck Protection Program (PPP), but called for the Small Business Administration (SBA) to address lender liability, provide timely feedback and update guidance pertaining to:

  • Reflect state-chartered credit unions are eligible to be PPP lenders;
  • Lender prioritization;
  • The use of SBA forms;
  • Purchasing process of loans.


“We ask Congress to ensure Treasury and the SBA simplify the forgiveness application process for loans under $350,000,” the letter reads. “This threshold would capture the vast majority of loans and is the amount at which the CARES Act makes the lowest cutoff in determining lender processing fees. Additionally, the agencies should consider making forgiveness of these loans automatic or simply require a good faith certification that the funds were spent on forgivable expenses.”

CUNA also urged Congress to take the following actions to support NCUA’s Central Liquidity Facility:

  • Expand the CLF’s borrowing authority to 25 times the paid in capital;
  • Extend the expanded borrowing authority until Dec. 31, 2021; and
  • Make permanent the ability of corporate credit unions to act as agents for credit unions.


The letter also expresses support for S. 3841, a bill introduced by Sens. Chuck Grassley (R-Iowa) and Sherrod Brown (D-Ohio) that would protect Economic Impact Payments from garnishment.