Removing Barriers Blog

Keeping member credit unions and leagues current on what and why we are doing for advocacy efforts including legislative, regulatory and state governmental affairs.
Posted February 28, 2021 by CUNA Advocacy

The House of Representatives will consider H.R. 1, the For the People Act of 2021 and H.R. 1280, the George Floyd Justice in Policing Act of 2021.

The Senate will begin consideration of H.R.1319, the American Rescue Plan Act of 2021.

Posted February 26, 2021 by CUNA Advocacy

CUNA submitted a comment letter to FHFA regarding its Enterprise Housing goals. FHFA is considering public comments received to inform rulemaking planned for 2021 to establish single-family and multifamily housing goals benchmark levels for 2022 and beyond and to make other changes to the Enterprise housing goals regulations, as appropriate. 

CUNA strongly supports the FHFA’s efforts to ensure that the GSEs meet their public mission and responsibilities to low-income and very-low income borrowers and communities.  

Posted February 26, 2021 by CUNA Advocacy

CUNA wrote to the FHFA regarding the Agency's request for information (RFI) on appraisal-related policies, practices, and processes. FHFA is seeking input on the current appraisal policies, practices, and processes, especially as they relate to modernizing the appraisal process and balancing mortgage lenders’ need for efficiency with the GSEs need for prudent risk management. The agency will consider the feedback received to determine the next steps for modifications and modernizations to the GSEs’ appraisal policies, practices, and processes.

CUNA supports the agency’s effort to assess and modernize the current GSEs’ appraisal policies, practices and processes. During this process, we recommend the FHFA consider the importance of permitting new valuation solutions – including virtual walk-throughs with local real estate agents or another qualified individual – that could beneficially augment traditional approaches to appraisals. Adopting modern appraisal solutions that leverage ubiquitous, improved technologies would greatly benefit rural areas that deal with unique challenges with traditional in-person appraisals. We also encourage the FHFA to revise its education and training requirements for new appraisers with an eye toward increasing the pool of individuals entering this critical vocation. 

Posted February 25, 2021 by CUNA Advocacy

CUNA and other trade organizations followed up a meeting with the Federal Communications Commission last week asking for error correction in the agency’s December 2020 Telephone Consumer Protection Act Report and Order.

The FCC exempted from the TCPA’s prior express consent certain informational calls in earlier orders. The December 2020 order limits the number of calls that may be placed under the Informational Calls Exemption to three calls within any consecutive 30-day period.

The organizations note, however, that in making the change the FCC amended a section of federal regulations in a manner that “appears to inadvertently” impose a prior express written consent requirement on informational calls made outside of the Informational Calls Exemption.

CUNA and other trade organizations followed up a meeting with the Federal Communications Commission last week with a letter sent Tuesday asking for error correction in the agency’s December 2020 Telephone Consumer Protection Act Report and Order.

The FCC exempted from the TCPA’s prior express consent certain informational calls in earlier orders. The December 2020 order limits the number of calls that may be placed under the Informational Calls Exemption to three calls within any consecutive 30-day period.

The organizations note, however, that in making the change the FCC amended a section of federal regulations in a manner that “appears to inadvertently” impose a prior express written consent requirement on informational calls made outside of the Informational Calls Exemption.

Posted February 25, 2021 by CUNA Advocacy

CUNA wrote to the Senate Small Business Committee prior to its hearing on the nomination of Isabella Casillas Guzman to lead the Small Business Administration (SBA). Credit unions helped facilitated more than 200,000 PPP loans that averaged $47,000.  The letter discussed how credit unions helped facilitated more than 200,000 PPP loans that averaged $47,000 and that additional PPP funding will likely be needed in 2021.

"Credit unions were proud participants in the Small Business Administration’s (SBA) Paycheck Protection Program (PPP). In fact, some credit unions were so eager to help their members through this program that they participated even though they had no previous relationship with the SBA. But, the quick implementation and slow bureaucracy at the SBA lead to significant and well documented problems for even the most experienced SBA lenders."

Posted February 25, 2021 by CUNA Advocacy

We wrote to Chairman Brown and Ranking Member Toomey prior to the Senate Banking Committee's hearing entitled, “The Coronavirus Crisis: Next Steps for Rebuilding Main Street.” We appreciate the work of Congress in crafting this legislative package to ensure that credit unions can continue helping Americans and small business to meet the challenges in 2021 and beyond.

“We appreciate the swift response that Congress has undertaken to address the economic consequences of the pandemic. More needs to be done, and still more will need to be accomplished in the months and years ahead,” the letter reads. “As financial first responders, America’s credit unions stand willing and able to help consumers and small businesses during the crisis and into recovery.”

Posted February 23, 2021 by CUNA Advocacy

CUNA wrote to the House Oversight and Reform Committee prior to the Committee's hearing discussing proposals to put the U.S. Postal Service on sustainable financial footing.  The letter urges Congress to explore ways to leverage the credit union system to bring about greater and more equitable financial inclusion, including field of membership updates.  Credit unions have a financial infrastructure already in place, as well as a long history of serving communities.

Posted February 23, 2021 by CUNA Advocacy

The NCUA, along with the federal banking regulators, issued a statement encouraging institutions operating in the affected areas to meet the financial services needs of their communities. The statement provides information on expectations of credit unions and other institutions affected by the Texas winter storms.

Posted February 22, 2021 by CUNA Advocacy

CUNA filed a comment letter in support of the NCUA’s proposed rule regarding requirements under the Bank Secrecy Act (BSA). 

Specifically, the proposal would allow the NCUA to issue exemptions from the requirements of its Suspicious Activity Reports (SARs) regulation.  Under the proposed rule, the NCUA would determine whether the exemption is consistent with the purposes of the BSA and with safe and sound practices, and may consider other appropriate factors. The NCUA would also seek FinCEN’s determination on whether the exemption would be consistent with the purposes of the BSA.

In issuing this proposed rulemaking, we appreciate the NCUA’s effort to provide a degree of regulatory relief as well as encourage credit unions to pursue innovative solutions to compliance requirements. We also believe it is important to maintain parity with the SARs regulations of the other federal financial regulators, which also have similar pending SARs proposals.

Posted February 21, 2021 by CUNA Advocacy

The House of Representatives and the Senate are expected to consider the “American Rescue Plan,” a $1.9 trillion piece of legislation that will be considered through the reconciliation process. The House will also consider H.R. 803, the Colorado Wilderness Act of 2021 as well as H.R. 5, the Equality Act. The Senate will also begin consideration of Linda Thomas-Greenfield to be U.S. Ambassador to the United Nations. 

Posted February 18, 2021 by CUNA Advocacy

The Board adopted a final rule that amends its share insurance regulation governing the requirements for a share account to be separately insured as a joint account by the NCUSIF. Specifically, the final rule provides an alternative method to satisfy the membership card or account signature card requirement necessary for insurance coverage. Under the final rule, even if a credit union cannot produce membership cards or account signature cards signed by the joint accountholders, the signature card requirement can be satisfied by information contained in the account records of the credit union establishing co-ownership of the share account. This final rule mirrors a 2019 change to the FDIC’s Deposit Insurance Fund regulations.

Posted February 18, 2021 by CUNA Advocacy

We wrote to Chairman Brown and Ranking Member Toomey prior to the Senate Banking Committee's hearing entitled, “The Coronavirus Crisis: Paving the Way to An Equitable Recovery.” Credit unions have been and continue to be America’s financial first responders during the COVID-19 pandemic and the ensuing economic fallout. CUNA, Congress, and the National Credit Union Administration (NCUA) have worked together to empower credit unions to effectively respond to the unique financial challenges of Americans in 2020. We appreciate the work of Congress in crafting this legislative package to ensure that credit unions can continue helping Americans and small business to meet the challenges in 2021 and beyond.

While we understand that the next round of COVID-19 relief legislation is being moved through Congress under the Budget Reconciliation process, which limits the inclusion of certain policies, we hope that additional attention will be given to policy changes that meet both the immediate needs of Americans, as well as long-term economic recovery.

Posted February 17, 2021 by CUNA Advocacy

Comments were submitted to the NCUA in response to the proposed overdraft policy is part of the agency’s proactivity in adapting rules, regulations, and policies to ensure credit unions can meet evolving needs of their members. 

Specifically, the proposal would remove the prescriptive 45-day limit for a member to cure each overdraft and replace with a requirement that the written policy establish a specific time limit that is both “reasonable and applicable to all members.”

The amended overdraft policy would still require the federal credit union to “establish a specific time limit” to cure the overdraft but it may exceed 45 days.

CUNA supports the agency’s proposed rule. COVID-19 has presented America’s credit unions and their members with extraordinary challenges. Despite the disruption of the past year, credit unions have continued to deliver high-quality financial services to credit union members throughout the duration of the pandemic. In that regard, we appreciate the agency’s proactivity as it has examined and adapted its rules, regulations, and policies to ensure credit unions have the tools necessary to meet the evolving needs of their members. The Overdraft Policy proposal is a perfect example of the agency’s ingenuity and we recommend the Board act quickly to implement the proposed change so that credit unions can amend their policies, as they deem appropriate, in the interest of assisting financially distressed members.

Posted February 17, 2021 by CUNA Advocacy

CUNA submitted comments to the Small Business Administration (SBA) in response to the request for comment regarding the implementation of the Payroll Protection Program (PPP) Second Draw Loans.  Credit unions continue to make PPP loans through the original and Second Draw programs to help small businesses survive the pandemic.

The Second Draw program allow certain eligible businesses to receive a second forgivable loan under generally the same terms and conditions available under the Paycheck Protection Program.

Posted February 14, 2021 by CUNA Advocacy
ON THE FLOOR The House of Representatives will have a committee work week and thus not consider any legislation on the floor this week. The
Posted February 14, 2021 by CUNA Advocacy

The National Credit Union Administration released its February Board meeting agenda for the meeting scheduled for Thursday – February 18th.  This will be the first meeting with Todd Harper as NCUA chairman. 

The Board will vote on a final rule on joint ownership share accounts which CUNA supports.  The proposal helps maintain parity with regulations that apply to banks and would explicitly permit the use of other evidence contained in a credit union’s account records to satisfy the signature card requirement for joint ownership of share accounts.

Posted February 11, 2021 by CUNA Advocacy

Comments were submitted to the NCUA on a proposal that would update the chartering manual’s service facility requirements which would help credit unions deliver necessary financial services to Americans.  CUNA strongly supports the proposal that would include any shared branch, ATM where the credit union is a member of the network, or electronic facility in the definition of “service facility” for a federal credit union adding an underserved area. 

“The proposed rule would make common sense changes to service facility requirements and reduces regulatory burden and confusion by harmonizing requirements for multiple common bond (MCB) credit unions for group and underserved area additions,” the letter reads, also noting that the proposed changes simplify requirements while adding necessary flexibility needed for credit unions to serve underserved areas. 

Posted February 10, 2021 by CUNA Advocacy

CUNA wrote to Chairwoman Waters and Ranking Member McHenry in advance of the House Financial Services Committee’s markup on the budget resolution (Reconciliation Pursuant to S. Con. Res. 5, the Concurrent Resolution on the Budget for Fiscal Year 2021) that allows the committee to spend $75 billion in reconciliation over a 10-year budget window.  

CUNA wrote supporting the inclusion of $9.961 billion allocated to states, territories, and tribes for direct assistance with mortgage payments, property taxes, utilities, and other housing costs.   

Posted February 07, 2021 by CUNA Advocacy

The House of Representatives will have a committee work week and thus not consider any legislation on the floor this week. The Senate will consider the nomination of Denis  McDonough to be Secretary of Veterans Affairs.

Posted February 04, 2021 by CUNA Advocacy

CUNA wrote to Chairwoman Waters and Ranking Member McHenry prior the House Financial Services Committee hearing Chairwoman Waters and Ranking entitled, “More than a Shot in the Arm: The Need for Additional COVID-19 Stimulus.”  Throughout the COVID-19 pandemic, we have seen economic disruption across the country with revenue streams coming to a halt and the number of unemployed or financially distressed consumers significantly increased.

CUNA urges Congress to take further legislative action to ensure that credit unions remain in a position to serve their more than 120 million members.

Posted February 04, 2021 by CUNA Advocacy

Next week, the National Credit Union Administration will hold a webinar on February 11 giving an update on Chairman Todd Harper's priorities and the agency's supervisory activities.  Additional information including registration links are in the NCUA's press release below.

Posted February 04, 2021 by jbrunson

CUNA wrote to the Small Business Administration reminding them that credit unions continue to be challenged by a slow approval process with the Paycheck Protection Program (PPP).  The PPP was re-authorized for up to $284 billion.

The letter details several examples of errors that have occurred during application processes.

Posted February 04, 2021 by CUNA Advocacy

State legislatures across the country have introduced legislation excluding sales tax from interchange fee assessments. These bills include Mississippi - MS HB 1076/SB 2856, Oklahoma - OK SB 798, and Tennessee - TN HB 375. Interchange fees, sometimes labelled as ‘swipe fees’, are an essential part of the electronic payments system, ensuring its safety and functionality. This fee helps pay for the benefits merchants receive from accepting electronic payments, including credit unions’ investments to protect consumers’ data and prevent fraud. 

Posted February 03, 2021 by CUNA Advocacy

The Consumer Financial Protection Bureau’s (CFPB) second Tech Sprint will take place March 22-26 and focus on the Home Mortgage Disclosure Act (HMDA). Tech Sprints gather regulators, technologists, financial institutions, and subject matter experts from key stakeholders for several days to work together to develop innovative solutions to clearly-identified challenges.

Posted February 01, 2021 by CUNA Advocacy

The NCUA has proposed to amend its investment regulation to permit FCUs to purchase mortgage servicing rights (MSRs) from other FICUs under certain conditions, such as that the underlying mortgage loans of the MSRs are loans the FCU is empowered to grant.

Today, we filed a comment letter in support the proposed rule to remove the prohibition against FCUs from purchasing MSRs as permissible investments while also maintaining safety and soundness. However, we recognize that the purchase of MSRs will not be appropriate for all FCUs given the risks and compliance considerations associated with MSRs.