Removing Barriers Blog

Letter to House in Support of Bill to Raise CFPB Exam Threshold
Posted November 30, 2015 by CUNA Advocacy

Today, we sent a letter to two members of the US House, asking them to support H.R. 4099, which would amend the Dodd-Frank Act by raising the asset threshold for supervision and examination from the Consumer Financial Protection Bureau. The current threshold is $10 billion in assets, which covers several credit unions. We support raising this threshold to relieve some of these credit unions of the burden of having to undergo regular and lengthy CFPB exams, on top of prudential exams from NCUA. 

H.R. 4099 would provide significant regulatory relief to the affected institutions and cause the Bureau to focus directly on the larger institutions and those that were previously unregulated. While this would not significantly change the number of institutions and percentage of assets presently subject to examination by the Bureau, it would allow the Bureau to more efficiently use its examination resources in the coming years. The number of financial institutions approaching $10 billion in total assets is increasing. As these institutions cross the threshold, the Bureau will be required to spend more of its resources examining these newly covered institutions at the expense of other important consumer protection activities.

While there are only a small number of credit unions subject to the cap today, we believe raising the cap beyond the asset size ceiling would be important recognition that credit unions were not the cause or perpetrators of the financial crisis and that credit unions, regardless of size, have a different incentive structure than for-profit financial institutions because they are owned by those they serve. For these reasons, we believe H.R. 4099 could be even stronger if it included a provision providing for automatic adjustment of the threshold indexed for inflation.