Comment Letters

Your comments are put into action in these letters sent by CUNA in response to regulatory proposals.

Listed below are all pending regulations for which CUNA has published a Comment Letter, regardless of current status. The listed date is the most relevant date for the status that the regulation is in: it could be the CUNA or agency due date, a Comment Letter publish date, or a Final Rule effective date, depending on whether the regulation is currently in the Call, Letter, or Analysis status.

Pending Changes can be sorted by any column in the green bar (Issue, Date, Agency, or Current Status), ascending or descending. For Comment Letters, a current status of "Closed" indicates the Letter has been sent to the agency. You can also use the "Archive" link at lower left for older items.

Please note: we now provide short summaries for significant Final Rules, which can be found on the same page as the comment letters. Our more detailed Final Rule Analyses are now available on the Compliance page

Issue Date Agency Current Status
Proposed Amendments to Prepaid Accounts Rules under Reg E and Reg Z 08/11/2017 CFPB Closed
2017 Regulatory Review 08/11/2017 NCUA Closed
CFPB RFC on Debt Collection Quantitative Disclosure Testing 08/08/2017 CFPB Closed
Appeals Process 08/07/2017 NCUA Closed
Supervisory Review Committee and Procedures for Appealing Material Supervisory Determinations 08/07/2017 NCUA Closed
Bylaws, Bank Conversions, and Mergers 08/07/2017 NCUA Closed
Treasury RFI on Regulations that can be Modified or Eliminated to Reduce Burden 07/31/2017 Other Closed
Assessment of Ability-to-Repay / Qualified Mortgage Rule 07/28/2017 CFPB Closed
Temporary HMDA Threshold Increase 07/27/2017 CFPB Closed
HUD RFI on Reducing Regulatory Burden and Enforcing the Regulatory Reform Agenda 06/14/2017 HUD Closed
CFPB RFI on the Credit Card Market 06/08/2017 CFPB Closed
Technical Corrections and Clarifying Amendments to the Home Mortgage Disclosure (Regulation C) October 2015 Final Rule 05/23/2017 CFPB Closed
Review of Remittances Rule 05/19/2017 CFPB Closed
Alternative Data 05/18/2017 CFPB Closed
DoD Limitations on Terms of Consumer Credit Extended to Service Members and Dependents 05/11/2017 Other Closed
Advance Notice of Proposed Rulemaking for Supplemental Capital 05/09/2017 NCUA Closed
CUNA Letter to Treasury Re Credit Union Roundtable(1) 04/27/2017 Other Closed
Prepaid Accounts - Proposed Delay 04/03/2017 CFPB Closed
FinCEN Update of SAR Fields 03/29/2017 FinCEN Closed
DOL Fiduciary Rule Delay 03/16/2017 Other Closed

Status Key

  • OPEN = CUNA seeking input to prepare comment to agency
  • CLOSED = CUNA comment filed, agency comment period closed
  • FINAL = Agency has issued final ruling