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 April 30, 2020 by CUNA Advocacy

NCUA Chairman Rodney Hood sent a letter to FASB urging them to exempt credit unions from complying with CECL. 

Hood’s letter states that, for most credit unions, implementing CECL will have an immediate impact on net worth, and though CECL extended implementation for credit unions by one year, credit unions are currently devoting maximum time and resources seeing members and businesses through the COVID-19 pandemic.

“I believe the compliance costs associated with implementing CECL overwhelmingly exceed the benefits,” Chairman Hood wrote. “Even before the current pandemic, credit unions had approached the NCUA with concerns about the unintended consequences of requiring credit unions to implement CECL. In our current environment, I am especially concerned that adopting CECL will have a chilling effect on lending, including loans to low-income borrowers."

Posted April 30, 2020 by Chandler Schuette

 NCUA Chairman wrote to Senator Crapo, Chairman of the Senate Banking Committee with suggestions Congress can make to improve the operating environment for credit unions. Many suggestions align with CUNA’s efforts raised during engagement with both NCUA and members of Congress in recent weeks.
 

Posted April 29, 2020 by CUNA Advocacy

The Small Business Administration (SBA) and the US Department of the Treasury (Treasury) announced that on April 29, 2020, from 4:00 PM EDT through 11:59 PM EDT,  the SBA systems will only accept PPP loan applications from participating lenders with asset sizes less than $1 billion.

This is intended to ensure access to the PPP loans for the smallest participating lenders and their small business members.

Participating lenders with asset sizes less than $1 billion can still submit PPP loan applications outside of this time frame. Participating lenders with asset sizes exceeding $1 billion can submit loans outside of today's 4 PM EDT through 11:59 PM EDT reserved submission time frame.

 

Posted April 29, 2020 by CUNA Advocacy

CUNA and other financial trade associations wrote to SBA Administrator Jovita Carranza to address continued concerns with the Paycheck Protection Program (PPP) loan submission process and E-TRAN access issues. 

“Unfortunately, with the start of the second round of funding many lenders are having significant problems submitting loan applications into the SBA’s system, preventing them from delivering this critical financial assistance to small businesses that desperately need it. Quite simply, it is taking too long to submit loans and get these funds where they need to go,” the letter reads. “We respectfully request that you help us resolve these access issues, or at least explain to our members what is causing the problem. 

Posted April 29, 2020 by dyi

The CFPB issued an interpretive rule and FAQ document regarding flexibility for its mortgage origination requirements. The actions taken address the TRID Rule’s 3-day waiting period requirements, Regulation Z’s consumer recession rights, and the ECOA and Regulation B’s appraisal and written valuation requirements in light of the COVID-19 pandemic

Posted April 28, 2020 by Chandler Schuette

CFPB Director Kathy Kraninger wrote to FCC Chairman Ajit Pai to voice her support for allowing financial institutions to use certain automated calls to alert consumers about relief options available to them during the COVID-19 pandemic without violating the Telephone Consumer Protection Act (TCPA).  Last week, CUNA wrote to the FCC asking the Commission to find that calls or texts relaying information related to financial relief efforts and other actions necessitated by the governments' response to COVID-19 fall within the emergency purposes exception to the proscriptions of the TCPA that bar autodialed calls to cell phones without prior consent.   

In this week’s letter, the CFPB Director stated the Bureau “has sought every avenue through stakeholders and fellow agencies to increase consumer awareness of the various relief options that may be available to them, including those available due to government actions and those made available by their financial institutions.” 

Posted April 28, 2020 by CUNA Advocacy

CUNA's President/CEO Jim Nussle was on CBS News’ Chief White House correspondent Major Garrett's podcast last night -- The Takeout. During the conversation, they discussed the credit union difference, PPP problems and his experiences in Congress and the administration during previous crises. 

condensed version of Nussle’s interview was also featured on the CBS News podcast, Debriefing the Briefing, in which Garrett and other CBS news correspondents break down the daily White House COVID-19 briefings.

Posted April 28, 2020 by CUNA Advocacy

CUNA wrote to the NCUA to follow up on previous communication with the agency.  The letter gives possible actions the NCUA could implement to alleviate the impact of the coronavirus disease. 

“CUNA continues to engage with credit unions of all sizes throughout the country to collect feedback within the industry,” the letter reads. “Based on recent communications with credit unions, we have the following policy recommendations for the NCUA to consider. These comments supplement CUNA’s previous communications with you, other members of the NCUA Board, and NCUA staff.”

Posted April 28, 2020 by CUNA Advocacy

The Treasury Department announced that the next Financial Literacy and Education Commission meeting will be on May 12th at 9:00 AM ET. 

The Financial Literacy and Education Commission was established under the Fair and Accurate Credit Transactions Act of 2003. The Commission was tasked to develop a national financial education web site (MyMoney.gov) and a national strategy on financial education. It is chaired by the Secretary of the Treasury and the vice chair is the Director of the Bureau of Consumer Financial Protection. The Commission is coordinated by the Department of the Treasury's Office of Consumer Policy.

Posted April 27, 2020 by dyi
The Small Business Administration today issued a Paycheck Protection Program related interim final rule regarding additional criterion for seasonal employees.  "Under section 1102 of the CARES Act, a seasonal employer may determine its maximum loan amount for purposes of
Posted April 27, 2020 by CUNA Advocacy

The Small Business Administration released information about steps the SBA and Treasury are implementing to help the next phase of PPP loan processing. 

Posted April 24, 2020 by CUNA Advocacy

Administrator of the U.S. Small Business Administration Jovita Carranza and Treasury Secretary Steven Mnuchin said the SBA will resume accepting Paycheck Protection Program (PPP) loan applications Monday, April 27 at 10:30 a.m. (ET) from approved lenders on behalf of any eligible borrower. President Donald Trump signed legislation Friday authorizing an additional $310 billion for the PPP.

“We encourage all approved lenders to process loan applications previously submitted by eligible borrowers and disburse funds expeditiously. All eligible borrowers who need these funds should work with an approved lender to apply,” Carranza and Mnuchin said in a joint statement.


Posted April 24, 2020 by CUNA Advocacy

CUNA wrote to all 535 Congressional offices reminding them that credit unions are there for their members and have been active participants in the SBA's Paycheck Protection Program.


Posted April 24, 2020 by CUNA Advocacy

Last night, CUNA wrote to Chairwoman Waters and Ranking Member McHenry urging the Committee to remove barriers preventing credit unions from fully serving their communities as Phase 4 of the COVID-19 relief legislation comes together. 

- Ensuring Small Businesses Can Access Credit from Credit Unions

- Ensuring Credit Unions Have Access to Sufficient Liquidity to Meet Members’ Needs 

Posted April 24, 2020 by CUNA Advocacy

President Trump recently signed legislation that was passed by both the House and Senate this week.  The legislation adds funding to the SBA's Paycheck Protection Program (PPP) which ran out of funding last week.  

"This important legislation will ensure that Main Street businesses and their employees can work with local credit unions to receive the financial support they need to see them through this crisis,” said CUNA President/CEO Jim Nussle. “Credit unions have been connecting community businesses with PPP funds since the program’s inception, and the $60 billion dedicated to community lenders, including credit unions, will especially go a long way to supporting small businesses that might have been unable to access the first round of funding.”


Posted April 24, 2020 by CUNA Advocacy

The Federal Reserve Board announced an interim final rule to amend Regulation D to delete the six-per-month limit on convenient transfers from the "savings deposit" definition. CUNA has urged the Federal Reserve to make this change for years, but recently increased its engagement on behalf of consumers during the COVID-19 pandemic.

“Today’s action by the federal reserve will make it easier for credit unions to give members access to their funds, which is vitally important as communities around the country deal with the impacts of the COVID-19 outbreak,” said CUNA President/CEO Jim Nussle. “We’ve long believed the threshold was arbitrary and unnecessary. We thank the Federal Reserve for making this critical change.” 


Posted April 23, 2020 by dyi

The NCUA sent a letter to credit unions on the appraisal changes made last week

Posted April 23, 2020 by CUNA Advocacy

The NCUA approved an interim final rule that amends the agency’s capital adequacy and member business loans and commercial lending regulations following the creation of the Small Business Administration’s Paycheck Protection Program

Posted April 22, 2020 by CUNA Advocacy

The CFPB released a video with the steps non-filers must take to receive their economic impact payments.

“The information we released today is intended to help consumers navigate the economic impact payments as well as helping them avoid scams related to the payments,” said Consumer Financial Protection Bureau Director Kathleen L. Kraninger.  “The Bureau stands ready to provide consumers with additional resources to protect their finances during this pandemic.”

Posted April 21, 2020 by CUNA Advocacy

The FHFA announced the alignment of Fannie Mae's and Freddie Mac's policies regarding servicer obligations to advance scheduled monthly principal and interest payments for single-family mortgage loans. Once a servicer has advanced four months of missed payments on a loan, it will have no further obligation to advance scheduled payments.  

This limit applies to all Enterprise servicers regardless of type or size.  

The intent of the policy is to provide mortgage servicers the ability to plan for exactly how long they will need to advance principal and interest payments on loans for which borrowers have not made their monthly payment.

The FHFA is also instructing the Enterprises to maintain loans in COVID-19 payment forbearance plans in Mortgage Backed Security (MBS) pools for at least the duration of the forbearance plan. This action clarifies that mortgage loans with COVID-19 payment forbearance shall be treated like a natural disaster event and will remain in the MBS pool. 

Posted April 21, 2020 by Chandler Schuette

The CFPB announced that the Consumer Advisory Board (CAB), Community Bank Advisory Council (CBAC), the Credit Union Advisory Council (CUAC), and the Academic Research Council (ARC) will meet jointly on May 1, 2020, from 2:00 to 4:15 pm ET via conference call.  The call will be open to the public. 

The meeting will focus on the COVID-19 pandemic, including a snap shot of consumer complaints as a result of the pandemic, and the impact of the pandemic on consumers, including servicemembers, students, older Americans, and the underserved.  

Those interested in listening to the meeting must RSVP here

Posted April 20, 2020 by dyi

UNA sent a letter urging the FCC to act more quickly on the petition for expedited declaratory rule, clarification, or waiver, filed by CUNA and other trade associations

Posted April 20, 2020 by dyi

CUNA and its members seek additional guidance on how Paycheck Protection Program (PPP) loans work in conjunction with NCUA’s member business lending requirements

Posted April 19, 2020 by CUNA Advocacy

On Sunday, CUNA wrote to Majority Leader McConnell, Speaker Pelosi, Leader Schumer, and Leader McCarthy encouraging Congress to appropriate the largest amount possible to the Paycheck Protection Program (PPP).  Additionally, the letter urges Congress to set aside a substantial portion of those fund for small lenders to ensure that small businesses are able to access funds from Main Street lenders, provided that such a set aside for small lenders does not delay the delivery of funds to small businesses, or complicate the approval process for lenders. 

The demand for these funds was so substantial that funds were exhausted within two weeks of implementation, leaving many small businesses across the country in the queue for loan approvals. Given the significant need that remains, it is critical that that Congress and the administration continue to support America's small businesses and their employees through additional PPP funding.   

Posted April 17, 2020 by CUNA Advocacy

Representative Brad Sherman (D-CA) was joined by Representatives Don Young (R-AK), Suzanne Bonamici (D-OR) Brian Fitzpatrick (R-PA) to introduce the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act. If enacted this legislation would exempt credit union business loans related to the COVID-19 pandemic from the member business lending cap for three years.

Currently law restricts most credit unions’ business lending authority at 12.25% of assets. But credit unions are well capitalized, safe and sound; credit unions for which this cap is limiting have significant business lending experience and additional capital to lend. Keeping this business credit on the sidelines during and after this crisis would make absolutely no sense.

After the bill's introduction, CUNA wrote to the sponsors in support of the legislation saying: 

“CUNA fully supports the Access to Credit for Small Businesses Impacted by the COVID–19 Crisis Act, which would provide a three-year exemption to the Member Business Lending cap for loans made by credit unions to aid in COVID-19 crisis relief and recovery. This legislation is targeted to the crisis at hand and will make a difference for America’s small businesses and those they employ."

Posted April 17, 2020 by CUNA Advocacy

The Small Business Administration's (SBA) Paycheck Protection Program (PPP) ran out of money on Thursday.  CUNA issued an action alert Friday for credit unions to contact policymakers to share the importance of the PPP funds and how additional funds will help credit unions continue their service during the pandemic.  In addition to the Action Alert, CUNA wrote to all 535 Congressional offices urging action to re-fund the program.

Designed to help small businesses meet payroll and other costs as they are impacted by the COVID-19 outbreak, the PPP was funded at $349 billion by the CARES Act.

Posted April 17, 2020 by CUNA Advocacy

CUNA wrote to Chairman Hood to seek additional guidance on how Paycheck Protection Program (PPP) loans work in conjunction with NCUA’s member business lending requirements. The PPP is a Small Business Administration program aimed at providing loans to small businesses impacted by the coronavirus disease (COVID-19) pandemic.

“We have recently heard from credit unions that they have concerns about how PPP loans work in conjunction with NCUA’s member business lending requirements,” the letter reads. “Furthermore, our members seek guidance on the impact of the Federal Reserve Board’s April 6, 2020 announcement of a Paycheck Protection Program Lending Facility (PPPL facility) to provide term financing backed by PPP loans and whether additional NCUA rulemaking is necessary to fully utilize this facility.”

Posted April 16, 2020 by dyi

The NCUA Board Meeting was called to order today at 10:00 a.m. EST. This was the first public meeting NCUA has had since adopting a telework posture nearly one month ago. The meeting was open to the public via a live webcast only. 

Posted April 16, 2020 by dyi

The NCUA sent a letter to credit unions regarding key changes to the NCUA’s Central Liquidity Facility (CLF).

Posted April 16, 2020 by CUNA Advocacy

The CFPB issued a final rule amending Regulation C to adjust the HMDA reporting thresholds for closed-end mortgage loans and open-end lines of credit.

Pursuant to the rule, effective July 1, 2020, the threshold for reporting data about closed-end mortgage loans will increase from 25 to 100 closed-end mortgage loans. CUNA supported this increase during the comment period but had called on the Bureau to establish a higher threshold.

In addition, effective January 1, 2022, when the current temporary threshold of 500 open-end lines of credit expires, the threshold for reporting data about open-end lines of credit will be permanently set at 200 open-end lines of credit.

Posted April 16, 2020 by CUNA Advocacy

CUNA wrote to Chairwoman Waters to engage on the Phase 4 of COVID-19 legislation. The letter comments on aspects of proposed legislation in the works, highlights areas where credit unions have concerns, and lists additional credit union priorities.

The COVID-19 pandemic has presented small businesses, consumers, and community-based financial institutions with an unprecedented challenge. Nonetheless, CUNA is confident that credit unions will be able to continue delivering critical financial services to members throughout the duration of the pandemic. 

Posted April 14, 2020 by CUNA Advocacy

CUNA wrote to all 535 Congressional offices prior to the Economic Impact Payments hitting accounts later this week.  The email reminded Congress and their staff about the work credit unions are doing to ensure their members are prepared and protected.

Posted April 16, 2020 by CUNA Advocacy

CUNA wrote to the National Conference of Commissioners of Uniform State Laws in regards to permitting electronic signatures on wire transfer documents.  This would allow credit unions to continue member service during the coronavirus disease (COVID-19) pandemic in a safe and sound manner.

Credit unions are committed to continuing to serve their members throughout the COVID-19 pandemic in a safe and sound manner that protects employees and members by complying with federal and state health and safety guidance. This has resulted in a technological shift away from in-person service of credit union members to electronic service as a result of stay-at-home orders and mandated social distancing.   

Posted April 16, 2020 by CUNA Advocacy

CUNA and Leagues wrote to Treasury Secretary Mnuchin about the challenges credit unions have been facing with implementing the PPP and concerns with the program.

Challenges with the program include:

  • Lack of support from the SBA
  • Loan closing concerns
  • Clarification on the disbursement of loans
  • Clarification on Forms.

Posted April 15, 2020 by CUNA Advocacy

The CFPB and FHFA announced a new “Borrower Protection Program,” a new joint initiative that enables the agencies to share servicing information to protect borrowers during the coronavirus national emergency.

Under the program, the CFPB will make complaint information and analytical tools available to FHFA via a secure electronic interface; and FHFA will make available to the Bureau information about forbearances, modifications and other loss mitigation initiatives undertaken by Fannie Mae and Freddie Mac (the Enterprises).

The CFPB has taken numerous steps to protect and assist consumers during the COVID-19 national emergency. For more information, the Bureau has developed a dedicated webpage with information on how consumers can protect their finances during the pandemic.

Posted April 15, 2020 by Chandler Schuette

The Small Business Administration, in consultation with the Department of the Treasury, issued a document of Frequent Asked Questions on the Paycheck Protection program

Posted April 14, 2020 by dyi

The NCUA sent out a risk alert suggesting cybersecurity considerations for remote work

Posted April 13, 2020 by dyi

The NCUA and the FDIC are hosting a free webinar to increase awareness of the benefits of federal deposit and share insurance, and answer questions about the safety of deposits at federally insured financial institutions.

Posted April 13, 2020 by CUNA Advocacy

The CFPB issued a policy statement on remittance transfers that outlined the Bureau’s plan to adopt a flexible approach to supervision and enforcement of remittance transfers. Previously, the Bureau proposed amendments to the Remittance Rule in December 2019 in part to address the effects of the expiration of that temporary exception and expects to issue a final rule in May.   

Posted April 09, 2020 by dyi

The NCUA Board meeting will be next week, on April 16. Due to the COVID-19 Pandemic, however, the meeting will be open via live audio webcast only.

Posted April 07, 2020 by dyi

financial institutions regulating agencies issued a revised interagency statement encouraging financial institutions to work constructively with borrowers affected by COVID-19 and providing additional information regarding loan modifications.

Posted April 07, 2020 by dyi

The Small Business Administration is scheduling a call regarding their lending programs. Any interested credit unions can join the call to get valuable information on these programs

Posted April 07, 2020 by dyi

The CUNA/American Association of Credit Union Leagues COVID-19 Response Center has been updated to include the latest guidance and materials on the Small Business Administration’s Paycheck Protection Program (PPP) and other government financial relief stemming from the COVID-19 pandemic

Posted April 06, 2020 by dyi

Staff from the Treasury Department and the Federal Reserve conducted a webinar where the main topic was the disbursement of Economic Impact Payments

Posted April 03, 2020 by CUNA Advocacy

CUNA's Chief Advocacy Office wrote to all 535 Congressional offices reminding them that credit unions are here and ready to help the millions of Americans that are facing bills and other issues with their finances being severely impacted by the coronavirus disease (COVID-19) outbreak.  

Posted April 02, 2020 by dyi

The Paycheck Protection Program (PPP) Small Business Administration (SBA) loans are an integral part of the CARES Act that President Trump signed into law last week.  

Posted April 02, 2020 by CUNA Advocacy


Posted April 01, 2020 by CUNA Advocacy

The CFPB released a policy statement outlining the responsibilities of credit reporting agencies and furnishers under the CARES Act. The Act requires lenders to report to credit bureaus that consumers are current on their loans if consumers have sought relief from their lenders due to the COVID-19 pandemic.

The policy statement informs lenders they must comply with the CARES Act and encourages lenders to continue to voluntarily provide payment relief to consumers and to report accurate information to credit bureaus relating to this relief.