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The intent of Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) is to facilitate enforcement of fair lending laws and enable communities, governmental entities, and creditors to identify business and community development needs and opportunities of women-owned, minority-owned, and small businesses. Credit unions strongly support the goal of this provision and seek to provide all members with opportunities such as the ability to start or own a small business when it is possible to do so. However, credit unions are concerned about the likely unintended consequences of having to collect additional data, which because of their diverse and unique fields of membership would not align with practices for collecting data by the large Wall Street banks and other financial service providers.
Credit unions, by their very mission, seek to provide safe and affordable products and services to consumers in need. While CUNA strongly supports the intent of Section 1071 and the Equal Credit Opportunity Act, there are serious concerns about unintended consequences that could result from a rule requiring additional data collection.
Requiring the collection of more data could do more harm than good by creating additional regulatory barriers for credit unions seeking to provide member business loans. Comparable data collection requirements as suggested by the CFPB in this RFI have proven to be extremely burdensome to credit unions and will likely impact credit union participation in the small business lending market. CUNA has been engaged with the CFPB on this issue for some time and will continue to urge the CFPB to tailor any data collection for credit unions.
CUNA submitted a comment letter to the CFPB with key points below:
This is in response to the Consumer Financial Protection Bureau's (CFPB) proposal to renew the Office of Management and Budget (OMB) approval for an existing information collection titled, “Generic Information Collection Plan for Consumer Comp
CUNA sent a letter to the CFPB regarding the proposal to renew the Office of Management and Budget (OMB) approval for an existing information collection, titled “Financial Coaching Program for Veterans and Low-income Consumers.”
Here are some key points:
Established as not-for-profit financial cooperatives
CUNA Advocacy | Dec 21, 2017
Vishnu Gawali | Nov 29, 2017
Senior Director of Advocacy & Counsel LDempsey@cuna.coop
The DOL finalized a rule defining who is a “fiduciary” of an employee benefit plan under the Employee Retirement Income Security Act of 1974 (ERISA), which included adding brokers and advisers providing advice to individual retirement accounts (IRAs).
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