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
Request to Develop Survey on POS/ATM Overdraft Disclosure 11/03/2015 CFPB Open
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
Joint Trade TCPA Express Consent Letter 03/10/2017 Other Closed
Consumer Access to Financial Records 02/15/2017 CFPB Closed
Private Flood Insurance 01/04/2017 NCUA Closed
Consumer Response Company Response Survey - Follow Up 12/12/2016 CFPB Closed
Letter for the NCUA’s Second FOM proposal 12/08/2016 NCUA Closed
Federal Home Loan Bank (FHLB) Membership for Non-Federally-Insured Credit Unions 11/28/2016 FHFA Closed
CFPB Rulemaking Moratorium 11/11/2016 CFPB Closed
RFI for Payday Loans, Vehicle Title Loans, Installment Loans, and Open-End Lines of Credit 11/04/2016 CFPB Closed
CFPB Small Dollar Proposal 11/01/2016 CFPB Closed
Disclosure of Records and Information Proposal 10/24/2016 CFPB Closed
FinCEN Requirements for Privately Insured Credit Unions 10/24/2016 FinCEN Closed
IRS Tax Transcript Processing Letter 10/21/2016 IRS Closed
CUNA Comment Small Dollar Loans Final Letter 20161005 10/05/2016 CFPB Closed
Consumer Survey re Complaint Closing Process 09/29/2016 CFPB Closed
Thank-You Letter to Director Cordray for Attending Financial Literacy Event 09/12/2016 CFPB Closed
Community Development Revolving Loan Fund 08/18/2016 NCUA 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