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The CFPB issues a final Advisory Opinions (AO) Policy to address regulatory uncertainty and provide guidance to covered entities.
Under the final Policy, any person or entity can submit a request for an AO via email to firstname.lastname@example.org. The Bureau will review the submissions received, prioritize certain requests for response, and issue opinions with a description of the incoming request. The Bureau may also decide to issue advisory opinions on its own initiative.
To increase transparency, the Bureau will publish all AOs in the Federal Register and on its website here.
As part of a joint trades group representing important financial services, health care and other industries, CUNA conducted outreach to Federal Communications Commission (“FCC” or “Commission”) staff regarding the Commission’s proposed Telephone Consumer Protection Act of 1991 (“TCPA”) robocalling regulations and requests for comments regarding current TCPA exemptions. The FCC’s recent TCPA notices were required by the Telephone Robocall Abuse Criminal Enforcement and Deterrence Act of 2019 (TRACED Act).
The joint trades emphasized that the FCC’s record clearly demonstrates the need for telephone providers to prevent erroneous call blocking and labeling of legitimate calls and to require quick and effective resolution of such errors. Examples of credit unions facing these problems were discussed, and the group reiterated the need for a 24-hour time-frame for resolution of such problems.
Register Now for Webinar on NCUA’s Response to COVID-19
ALEXANDRIA, Va. (Nov. 16, 2020) – Federally insured credit unions can learn more about the National Credit Union Administration’s response to the COVID-19 pandemic by participating in a webinar hosted by the agency on Thursday, December 3, beginning at 1 p.m. Eastern.
During the webinar, NCUA staff will also discuss recently issued guidance and regulations, as well as other agency initiatives.
The Senate will resume consideration of Taylor B. McNeel, of Mississippi, to be United States District Judge for the Southern District of Mississippi.
The House of Representatives will consider H.R. 3884, the MORE Act of 2019.
CUNA submitted comments to the Federal Reserve Board and the Financial Crimes Enforcement Network (FinCEN) in response to their joint notice of proposed rulemaking (JNPRM) lowering the threshold for collection, retention and transmittal of information for international funds transfers, and clarifying the treatment of convertible virtual currencies and other assets with legal tender status. Most significantly, the proposal would lower this critical threshold from transactions valued at $3,000 and above to $250 and above.
The NCUA and other Federal financial regulators issued a joint fact sheet regarding compliance efforts required to meet Bank Secrecy Act (BSA) due diligence requirements for customers that are charities and other nonprofit organizations.
In the joint statement, the agencies stated that the due diligence efforts should be based on the money laundering risks posed by the customer relationship. The clarification was issued to recognize that legitimate charities and nonprofits deserve and benefit from access to financial services, and “do not present a uniform or unacceptably high risk of being used or exploited for money laundering, terrorist financing, or sanctions violations . . ..” Accordingly, the due diligence expected of credit unions and other banks should be based on the risk profile of individual charitable customers, and the fact sheet gives examples of useful customer data that credit unions may want to collect to help determine those risks.
The fact sheet was developed and disseminated by the National Credit Union Administration, the Federal Reserve Board, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network, and the Office of the Comptroller of the Currency.
NCUA Chairman Hood sent a letter to federal credit unions outlining relief measures around meeting flexibility due to the COVID-19 pandemic. CUNA has been advocating for these changes during meetings with the NCUA over the past few months.
The Board issued a proposed rule to allow the capitalization of interest in connection with loan workouts and modifications. The proposal would remove the current prohibition on capitalizing interest, which according to the agency “may be overly burdensome and, in some cases, hamper a federally insured credit union’s good-faith efforts to engage in loan workouts with borrowers facing difficulty because of the economic disruption that the COVID-19 event has caused.”
Earlier this week, CUNA wrote to Chairman Shelby and Ranking Member Leahy regarding the Committee’s release of twelve fiscal year 2021 appropriations bills.
Credit unions have interest in several programs and report language included in these bills and as we continue to endure the
COVID-19 pandemic and ensuing e
CUNA joined 80 other trade associations in writing to Congressional, Treasury and Small Business Administration leadership with concerns over a new Paycheck Protection Program (PPP) review process established by the Treasury and SBA that includes “Loan Necessity Questionnaires.”“Unfortunately, the questionnaires introduce a confusing and burdensome process for both borrowers and lenders, and we fear that it could lead the agencies to inappropriately question thousands of qualified PPP loans made to struggling small businesses,” the letter reads. “On behalf of the millions of American workers supported by PPP loans, we urge you to act quickly to work directly with SBA and Treasury to avoid this unintended consequence.”
CUNA has submitted comments to the Financial Crimes Enforcement Network (FinCEN) in response to its advance notice of proposed rulemaking (ANPRM) on anti-money laundering (AML) program effectiveness.
The ANPRM provided a broad definition of an “effective and reasonably designed” AML program as one that:
Reminder that NCUA will be conducting two webinars this week.
PALs and Short-Term Lending Webinar
TODAY: Monday, Nov. 16 at 3:00 p.m. – 4:00 p.m. EST
Fair Lending and Consumer Compliance Regulatory Update Webinar
Tomorrow: Tuesday, Nov. 17 at 3:00 p.m. – 4:00 p.m. EST
The Senate will convene at 3:00 pm on Monday and resume consideration of Kristi Haskins Johnson to be a United States District Judge for the Southern District of Mississippi. The House of Representatives will consider H.R. 8294, the National Apprenticeship Act of 2020.
NCUA’s proposed 2021–2022 budget is now available for review and comment. The proposed budget summary and detailed budget justification are available on the Budget and Supplementary Materials page of NCUA.gov. Comments must be emailed to NCUA at BudgetComments@ncua.gov by Dec. 11.The agency will hold a public budget briefing on Wednesday, Dec. 2 beginning at 10 a.m. (ET).
The CFPB announced that next Combined Advisory Committee Meeting is scheduled to occur on the afternoon of November 18.
The focus of the meetings will be broad policy matters related to the Bureau’s Unified Regulatory Agenda and general scope of authority, including:
Those interested in streaming the meeting via WebEx can RSVP here.
CUNA wrote to Chairwoman Waters and Ranking Member McHenry prior to the House Financial Services Committee hearing with financial regulators. In the letter, CUNA wrote that the NCUA and Congress should take further steps to ensure credit unions remain in position to serve members during and after the pandemic. NCUA Chairman Rodney Hood testified at the hearing, which also featured discussion of two CUNA-backed bills.
The National Credit Union Administration (NCUA) released the agenda for the November Board meeting scheduled for 10:00 AM ET on November 19th.
CUNA wrote to Chairman Crapo and Ranking Member Brown prior to the Senate Banking Committee's hearing with financial regulators. In the letter, CUNA wrote that credit unions remain in a position to help consumers, but looming stress suggests Congress and regulators need to act quickly to avoid a deeper economic crisis. CUNA’s letter notes two surveys that indicate significant economic assistance to consumers and small businesses is critically important.“As Congress contemplates further COVID-recovery legislation and exercises its oversight responsibilities over the Federal financial regulators, it is critical that policy be examined and modified to ensure credit unions remain in a position to serve their members throughout and after this crisis,” the letter reads.
The FHFA announced the validation and approval of the Classic FICO credit score model for use the Enterprises. The validation and approval of Classic FICO by the Enterprises allows them to continue supporting the mortgage market while assessing more modern credit score models.
CUNA weighed in on the FHFA’s 2018 request for comment regarding use of several credit score models by the Enterprises. In our letter, we stressed the importance that the FHFA work to find the right balance between safety and soundness on the one hand, and credit availability for American consumers on the other. Having a housing finance market that provides liquidity throughout the country requires strong participation by a wide range of lenders, including small lenders and lenders serving rural areas. Qualified financial institutions and creditworthy eligible borrowers should have fair and equitable access to the financial services offered by the Enterprises.
The Senate will convene at 3:00 pm on Monday and resume consideration of James Ray Knepp II to be a United States District Judge for the Northern District of Ohio. The House of Representatives will be in pro forma session this week.
CUNA submitted comments to the Treasury in response to the recently proposed potential revisions to the application as part of its ongoing review of policies and procedures. In the letter, CUNA wrote that the proposed Community Development Financial Institution (CDFI) Certification Application is flawed and should be reconsidered.“While CUNA supports the CDFI Fund’s ongoing efforts to evaluate and consider the efficiency and relevance of its certification and monitoring process, we strongly believe the proposed revisions to the certification application fail to achieve these goals nor would they further the purposes of the CDFI Program,” the letter reads. “In fact, the proposed application changes could ultimately serve as unnecessary barriers for qualified credit unions to access the CDFI designation.”
CUNA has filed reply comments with the Federal Communications Commission (FCC) for its regulatory review of certain exemptions to the Telephone Consumer Protection Act (TCPA). The review was mandated by the Telephone Robocall Abuse Criminal Enforcement and Deterrence Act (TRACED Act).
In its letter, CUNA argues that “the initial comments demonstrate overwhelming support for retaining the current exemptions, particularly the exemption for commercial informational calls to residential lines, without imposing additional restrictions.” The letter also points out the importance of such critical informational calls to credit union members, and highlights submitted comments against arbitrary caps or “opt out” requirements. In addition, CUNA echoed trade group requests for modest modifications to the financial services exigency exemption to make it more effective, and reiterated its longstanding request for the FCC to extend existing residential informational call exemptions to wireless phones.
The NCUA will host a webinar on November 17th where staff from the NCUA’s Office of Consumer Financial Protection will discuss the focus areas for the agency’s consumer compliance exams in 2021, including a review of COVID-19-related loan modifications and credit reporting, and fair lending policies and procedures. The discussion will also include the findings from the 2020 consumer compliance exam reviews.
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