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CUNA joined with a number of trade, consumer, and civil rights organizations to request that the Federal Reserve, Federal Housing Finance Agency, Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, Securities and Exchange Commission, and Department of Housing and Urban Development delay any conclusion from their re-evaluation of the Qualified Residential Mortgage (QRM ) definition until after the Consumer Financial Protection Bureau finalizes and implements the changes it is considering to the Qualified Mortgage (QM) definition. Each agency was required to start reviewing the regulation by December 24, 2019, in accordance with the timeline set forth in the original QRM rule.
CUNA submitted a comment letter in response to the FCC's request for input on call blocking. The information provided is being used by the FCC to generate its first staff report on the deployment, use, and effectiveness of the newly implemented call-blocking regime. In the comment letter, CUNA reiterates concerns about the use of call blocking technologies to block or mislabel the legitimate, and often critical, calls that credit unions make to the members--such as calls notifying the member of potentially fraudulent activity with their account. As a result of the potential for harm, the letters urges the FCC to adopt an effective challenge mechanism and goes on to explain that, in order to be effective, the challenge mechanism must require use of real time notifications of call blocking, readily ascertainable contact information to lodge concerns with providers and trigger a review process, and a commitment to promptly resolving erroneous blocking.
CUNA's Chief Advocacy Officer wrote to all 535 Congressional offices highlighting how credit unions provide everything from short-term emergency loans to future-building investments like mortgages and small business loans.
Last week, NCUA announced
several staff changes worth noting.
This week, the Senate will continue its impeachment proceedings against the President.
The House of Representatives will consider H.R. 3621, the Student Borrower Credit Improvement Act [Comprehensive CREDIT Act of 2020]. In addition, the House will vote to repeal certain war powers of the president.
The NCUA board issued a proposed rule on credit union combination transactions and subordinated debt, among other items, at its board meeting. The agenda also included approval of the agency’s 2020 Annual Performance Plan and a briefing on the credit union loan interest rate ceiling.
The CFPB issued a policy statement outlining its approach to the “abusiveness” standard in supervision and enforcement matters.
CUNA, CrossState Credit Union Association, the Illinois Credit Union League, and the New York Credit Union Association wrote to the NCUA urging them to refrain from selling their entire taxi medallion loan portfolio to for-profit debt buyers.
Selling the portfolio may harm not only the credit unions holding taxi medallion loans but ultimately all federally insured credit unions due to the effect on the National Credit Union Share Insurance Fund. NCUA selling its portfolio of taxi medallion loans is not an appropriate step at this time.“We urge the NCUA to refrain from such a sale and to instead engage with CUNA, the state leagues, and credit unions—both those directly and indirectly involved. Such collaboration could bring about a more creative solution than simply selling the entire loan portfolio to a single investor at a significant loss,” the letter reads. “While such a sale may be the quickest and easiest approach for the agency, it is not in the best interest of credit unions and their members, including borrowers who took out loans to obtain taxi medallions.”
The NCUA should refrain from selling the entire taxi medallion loan portfolio to for-profit debt buyers for several reasons:
CUNA wrote the CFPB in response to their proposed rule making several changes to the remittance rule, including raising the “normal course of business threshold” to 500 remittance transfers per year. In the letter, CUNA wrote that the CFPB should explore several revisions and additions to its remittance rule.
The CFPB’s remittance rule establishes consumer protections for covered international money transfers. CUNA’s outreach to Leagues and credit unions regarding the rule’s impact has shown that the compliance resources needed to offer the service has led many credit unions to discontinue offering it.
ON THE FLOOR
This week, the House of Representatives is in recess. The Senate will begin the impeachment trial of the president.
No Committee meeting of note have been ann
CUNA continued outreach to Capitol Hill in an email to all 535 Congressional offices from Chief Advocacy Officer, Ryan Donovan. This email aligns with CUNA’s advocacy focus for 2020, highlighting to policymakers the difference credit unions make for their members every day.
The NCUA will hold their January Board meeting on Thursday, January 23rd at 10:00 AM in Alexandria, VA. Below you can find the agenda for the open session.
CUNA and the Mountain West Credit Union Association (MWCUA) joined forces in sending a letter to the Colorado Banking Board in support of Elevations CU's plan to purchase and assume Cache Bank & Trust. The Board must approve this transaction, and the Colorado Bankers Association (CBA) has asked the board to consider the legality of the transaction.
Specifically, Cache Bank & Trust has requested authorization to operate as if the bank was a national bank, a request that includes the approval of the purchase and assumption by Elevations CU.CUNA President/CEO Jim Nussle and MWCUA President/CEO Scott Earl wrote how such credit union-bank transactions are good business decisions for all parties involved.
CUNA wrote to Chairman Sherman and Ranking Member Huizenga prior to the House Financial Services Subcommittee on Investor Protection, Entrepreneurship and Capital Markets prior to their hearing entitled, “An Examination of the Financial Accounting Standards Board and the Public Company Accounting Oversight Board.” In the letter, CUNA wrote how the Financial Accounting Standards Board’s (FASB) current expected credit losses (CECL) standard will have a significant impact not only on covered financial institutions but also consumers and the broader economy.During the hearing, Representative Blaine Luetekemeyer of Missouri cited a CUNA study showing it will cost credit unions $14-15 billion to implement CECL.
CUNA wrote to Speaker Pelosi and Leader McCarthy in support of two bills prior to their consideration on the House floor. Both bills passed the House Financial Services Committee with strong bipartisan support.
H.R. 5315, the Expanding Opportunities for Minority Depository Institutions Act If enacted, H.R 5315 would codify the Treasury Department’s mentor protégé program to encourage collaboration between Minority Depository Institutions and large financial institutions
H.R. 4458, the Cybersecurity and Financial System Resilience ActIf enacted, H.R. 4458 would require federal regulators to each issue an annual report to Congress describing measures it has taken to strengthen cybersecurity.
In early December, the CFPB issued a proposed rule on remittances that would increase the “normal course of business” threshold to 500 transfers per year, up from 100. While a positive step forward, CUNA has recommended the Bureau raise the threshold to at least 1,000 transfers.
In addition to raising the “normal course of business” threshold, the proposal would also establish two permanent exemptions allowing certain credit unions to continue to provide fee estimates where it could be economically infeasible for to provide exact amount disclosures.
If you are interested in submitting comments on this important proposal impacting credit unions, you can visit CUNA’s grassroots action center here.
Comments are due to the CFPB by January 21, 2020.
The CFPB is currently accepting applications to serve on the Bureau’s four advisory committees: the Consumer Advisory Board, the Community Bank Advisory Council, the Credit Union Advisory Council, and the Academic Research Council. These groups provide the Bureau with important feedback about emerging trends and practices in the consumer financial marketplace.
Applications are being accepted until February 27, 2020.
The House of Representatives will consider H.R. 1230, the Protecting Older Workers Against Discrimination Act and H.J. Res. 76, “providing for congressional disapproval of the rule submitted by the Department of Education relating to "Borrower Defense Institutional Accountability." In addition, the House will consider under suspension of the rules a number of financial services bills.
The Senate will convene Monday and resume consideration of Peter Gaynor to be Administrator of the Federal Emergency Management Agency. The Senate may begin the impeachment trial of President Trump.
NCUA issued a letter to credit unions describing supervisory priorities for 2020, as well as addressing NCUA’s efforts to continue to modernize the examination program.
NCUA identified the following supervisory areas it will focus on in 2020:
For more on what specifically NCUA will look at in each of this areas, see CUNA’s Compliance Blog post: Examination Priorities for 2020.
The CFPB issued a release announcing the members of its Taskforce on Federal Consumer Financial Law. The Taskforce will examine the existing legal and regulatory environment and deliver recommendations on ways to improve and strengthen consumer financial laws and regulations.
The four Taskforce members are:
CUNA and representatives from six credit unions participated in a financial institution roundtable on developing and implementing successful savings programs for consumers. The meeting included a diverse group of financial institutions, including large banks, community banks, credit unions, and insurance companies.
The roundtable began with opening remarks from CFPB Director Kathy Kraninger who has sought to increase consumer awareness about the importance of savings through the Bureau’s Start Small, Save Up Initiative. Following the Director’s remarks, the participants heard presentations on emergency savings strategies and lessons learned from financial entities that developed successful programs. BECU presented on the credit union's early saver program and how to leverage technology to reach vulnerable members. The meeting also included breakout sessions to discuss helping consumers and workforce build emergency savings, marketing, and research.
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© 2020 Credit Union National Association
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