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CUNA continues to push on the Federal Communication Commission's draft declaratory ruling on default block calling, this time with a letter to Secretary Marlene Dortch.
CUNA sent a comprehensive letter to NCUA detailing a number of issues the agency should address as part of its annual, one-third regulatory review.
CUNA wrote in favor of an Amendment that would ensure credit unions would be represented on the Consumer Advisory Board (CAB) at the CFPB. The Amendment was offered by Representative Haley Stevens and it passed with a 418-10 vote.
The CFPB’s CAB is an important tool in identifying and assessing consumer financial practices, trends, and products and providing recommendations. However, there is no requirement that representatives of credit unions, community banks, or small businesses be appointed to serve on the board. Currently, there is no credit union representation on the CAB.
The NCUA Board issued a proposed rule on nonmember deposits, received an update on the work of CURE, and received its quarterly briefing on the status of the Share Insurance Fund. Chairman Hood thanked members of the Northwest Credit Union Association for their attendance at today’s meeting.
CUNA wrote to Senator Tillis (R-NC) in support of his recently introduced legislation to stop and study Current Expected Credit Loss (CECL). If enacted, S. 1564, the Continued Encouragement for Consumer Lending Act would require the standard (CECL) to be delayed and studied by the Securities and Exchange Commission along with the federal financial regulators, including the NCUA.
The CFPB announced that their financial education tool called "Misadventures in Money Management" has been expanded to active-duty servicemembers. According to mimm.gov, "Misadventures in Money Management was developed in partnership with the Consumer Financial Protection Bureau’s (CFPB) Office of Servicemember Affairs (OSA) and WILL Interactive. It aims to help military service members improve their financial literacy and financial choices through an interactive graphic novel experience."
CUNA continued its push for regulatory intervention on the Federal Communications Commission’s draft declaratory ruling on default call blocking, this time to Consumer Financial Protection Bureau Director Kathy Kraninger. CUNA’s letter urges Kraninger to intervene with the FCC and ask the agency to delay and reconsider the ruling, particularly since the CFPB is a strong proponent of ensuring consumers are protected by being aware of important account information.
The order would allow voice service providers to default block robocalls, requiring consumers to opt in to receive such communications. The FCC is scheduled to vote on the order June 6.
Last week, CEOs of major financial services trade associations came together with a message to all U.S. financial institutions: Join Sheltered Harbor. Check out this deeper dive by Sheltered Harbor CEO Trey Maust into why the initiative is critical - both for individual institutions' operational resilience, and for the stability of the financial system as a whole.
CUNA's Economics and Research team recently released an updated SIF Distribution Calculator. Check it out to get your best estimate of first quarter 2019 CU SIF equity distribution.
Check it out!
The CFPB published its Spring 2019 rulemaking agenda as part of the Unified Agenda of Federal Regulatory and Deregulatory Actions, which is coordinated by the Office of Management and Budget (OMB). As an independent regulatory agency, the Bureau voluntarily participates in the Unified Agenda.
The next Credit Union Advisory Council (CUAC) meeting is scheduled to occur over two days on June 5-6
CUNA sent a letter to NCUA asking it to consider the pros and cons of replacing the existing fixed interest rate cap on FCU loans with a floating rate cap.
NCUA Chairman Hood announced that he has appointed Lenwood Brooks as the Assistant to the Chairman and Director of External Affairs. Mr. Brooks joins the NCUA from the Securities Industry and Financial Markets Association, where he served as Vice President of Communications and led the trade association’s external affairs activities. His position reports directly to the Chairman and he will manage the agency’s Office of Public and Congressional Affairs as well as intergovernmental and stakeholder relations.
Comments were submitted to the Department of Labor (DOL) in response to the current proposed overtime regulation under the Fair Labor Standards Act (FLSA). While the proposal is an improvement over the 2016 overtime rule, CUNA urges DOL to avoid creating excessive costs and compliance burdens on credit unions.
The proposal attempts to strike a balance between ensuring the salary level test is consistent with present day practice while also avoiding a sudden jolt to the resources of small employers.
CUNA sent its serious concerns about the Federal Communications Commission’s (FCC) scheduled June 6 vote on default call blocking to the attention of NCUA Chairman Rodney Hood, and requested he intervene and ask that FCC delay and reconsider the ruling.
Last week, FCC Chairman Ajit Pai said that the FCC will vote on an order that would allow voice service providers to default block robocalls, only lifting the block once a consumer has specifically opted in to receive communications.
CUNA wrote to Chairman Crapo and Ranking Member Brown prior to the Senate Banking Committee’s hearing entitled, “Combating Illicit Financing by Anonymous Shell Companies Through the Collection of Beneficial Ownership Information.”
The letter wrote of CUNA and credit union support for reasonable protections, including those under the Bank Secrecy Act (BSA), aimed at reducing financial crimes.
“Credit unions take BSA/AML compliance seriously and dedicate significant resources to it. However, when credit unions are spending their limited resources disproportionately on compliance, this means they are spending fewer resources on innovating and providing safe and affordable products and services.”
CUNA submitted a brief in support of Navy Federal Credit Union to the U.S. Court of Appeals for the Fourth District, in response to a decision by the U.S. District Court for the Eastern District of Virginia that found Section 1332 of the U.S. Code is the sole source of diversity jurisdiction and that Section 1332 does not apply to federally chartered corporations. CUNA supports federal credit unions’ access to federal courts via diversity jurisdiction, one of the two methods for a federal court to have jurisdiction. CUNA’s brief, filed in Navy FCU v. LTD Financial Services et al, says that by foreclosing the ability for federal credit unions to invoke diversity jurisdiction, the court has failed to give effect to Congressional intent to treat federal and state credit unions alike in all material respects.
A reminder that NCUA is seeking comments on its 2019 annual regulatory review until June 1. NCUA reviews all of its existing regulations every three years. NCUA’s Office of General Counsel maintains a rolling review schedule that identifies one-third of the NCUA’s existing regulations for review each year.
MarketWatch published an article interviewing Rachel Pross the Chief Risk Officer at Maps Credit Union in Oregon and myself about cannabis banking. Our interviews focused on the cannabis banking movement in Congress and highlights the work we’ve both been doing to create a safe and efficient ways for cannabis businesses have access to financial services. We both agree, cannabis banking can be conducted safely and efficiently – we just need common-sense federal laws and regulations.
CUNA wrote to NCUA Chairman Hood congratulating him on his appointment as Chair of the National Credit Union Administration and to provide additional information not included in a March letter that was sent during the confirmation process. CUNA and our members look forward to working with with the Chairman and are eager to stand as a resource.
The House of Representatives will consider H.R. 1500, the Consumers First Act as well as H.R. 1994, the Setting Every Community Up for Retirement Enhancement Act of 2019.
The Senate will convene on Monday and resume consideration of Daniel P. Collins to be a United States Circuit Judge for the Ninth Circuit.
The House Oversight Committee held a hearing entitled, “CFPB’s Role in Empowering Predatory Lenders: Examining the Proposed Repeal of the Payday Lending Rule." Prior to the hearing, CUNA wrote to Chairman Cummings and Ranking Member Jordan explaining how credit unions provide consumers with access to small dollar credit on safe and affordable terms. CUNA also included a comment letter on the CFPB's Payday Rule that was submitted to the CFPB this week.
CUNA wrote to Chairman Nadler and Ranking Member Collins prior to the Judiciary Committee’s hearing on “Justice Denied: Forced Arbitration and the Erosion of Our Legal System.”
The letter highlighted the credit union difference and the many consumer protections associated with the credit union mission.
"As one of the only consumer-owned cooperatives in the financial marketplace, credit unions have a long tradition of protecting their members’ interests. Among the many consumer protections associated with the mission of credit unions is the high-quality service they provide to their members, which has prompted a successful system for quickly and amicably resolving disputes in the limited instances where they arise. Credit unions have achieved this great success as consumer protectors without the intervention of unscrupulous plaintiff’s attorneys, who often do not know the credit union’s members nearly as well as the credit union does. Arbitration can be an efficient means to resolve legal disputes between parties and the choice to use arbitration is highly dependent on each credit union’s internal policies, priorities, and resources."
CUNA wrote to Chairman Doyle and Ranking Member Latta prior to the House Energy and Commerce Subcommittee's hearing on “Accountability and Oversight of the Federal Communications Commission.”
It is imperative that Congress encourage the FCC to modernize its implementing regulations for the Telephone Consumer Protection Act (“TCPA”). Credit unions are tax-exempt nonprofit democratically operated financial cooperatives that have a unique relationship with their members, who are also owners of the enterprise. This special relationship spawns a variety of communications between the credit union and its member-owners, ranging from timely and critical financial information to messages regarding governance issues and financial education. Members welcome and expect this information
The House Financial Services Committee held a hearing with the financial regulators similar to this week's Senate Banking Committee hearing. During the hearing, Members of the Committee cited CUNA data on the current expected credit loss (CECL) standard. CUNA wrote to Chairwoman Waters and Ranking Member McHenry prior to the hearing raising the CECL concerns, as well as praising NCUA for its modernization efforts and listing several improvements NCUA could make -- this letter was similar to the letter sent to Chairman Crapo and Ranking Member Brown in the Senate Banking Committee.
issues an Accounting
Standards Update (ASU) intended to ease transition to the CECL credit
losses standard by providing the option to measure certain types of assets at
CUNA submitted comments to the Consumer Financial Protection Bureau (CFPB) in response to their proposal to rescind the mandatory underwriting provisions within the payday rule. CUNA wrote that the short-term, small-dollar (payday) rule would have a detrimental impact on access to consumer-friendly credit union products if implemented unchanged.
CUNA believes the rule fails to strike an appropriate balance between enhancing consumer protection and ensuring credit unions are able to continue serving their members.
“CUNA strongly urges the Bureau to amend the rule to avoid causing any negative effects on credit unions’ small dollar loan programs and, instead, refocus the rule on appropriately reining in unregulated and underregulated non-depository online, payday, and title lenders, particularly entities with a history of bad behavior,” the letter reads. “To achieve this goal, CUNA recommends the Bureau use its broad exemption authority under Section 1022(b)(3)(A) of the Dodd-Frank Act to exempt all small dollar loans offered by credit unions from the 2017 Payday Rule, as credit unions have set themselves apart from other actors in this market.”
CUNA wrote to Chairman Kennedy and Ranking Member Coons prior to the Appropriations Committee's
hearing to “Review the FY2020 Budget Request for the U.S. Department of Treasury.” In the letter, CUNA urged the Committee to increase federal funding for the Community Development Financial Institutions (CDFI)
The Senate Banking held a hearing entitled “Oversight of Financial Regulators." NCUA Chairman Hood was on the witness panel. Prior to the hearing, CUNA wrote to Chairman Crapo and Ranking Member Brown with steps the NCUA should take toward enhancements to the credit union charter, while improving cybersecurity efforts and reducing regulatory burden.
The hearing brought together leading officials from the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board of Governors (“Fed”), Federal Deposit Insurance Corporation (FDIC), and the NCUA. Collectively, the primary topics of discussion included conversation on the state of the financial regulatory system, the Community Reinvestment Act, and updates on ongoing and past regulatory actions.
CUNA wrote to the Senate Banking Committee, House Financial Services Committee, and to Committee members and their staff prior to NCUA Chairman Rodney Hood’s testimony before both Committees this week. Chairman Hood will appear before the Committees as part of a panel of federal financial regulators.
In the letters, CUNA wrote that the NCUA should take steps toward enhancements to the credit union charter, while improving cybersecurity efforts and reducing regulatory burden.
The credit union industry has focused its advocacy efforts on enhancements to the credit union charter. Therefore, we urge the agency to take steps toward this objective, which may include collaborating with parties outside NCUA. Concern over cyber and data security is likely the single biggest issue currently facing most industries, including financial services.
The CFPB published a notice announcing plans to periodically review regulations under the Regulatory Flexibility Act (RFA). As part of its RFA Review, the Bureau has issued a notice requesting public comment on the 2009 Overdraft Rule.
Section 610 of the RFA requires agencies to review certain rules within 10 years of their publication, and consider the rules’ effect on small businesses. The purpose of the review is to minimize any significant economic impact of the rules upon a substantial number of small entities. At the conclusion of each review, the Bureau will determine whether the rule should be continued without change, or should be amended or rescinded.
CFPB Director Kathy Kraninger announced that Brian Johnson will serve as the Deputy Director. Mr. Johnson first joined the Bureau in December 2017 as Senior Advisor to the Director and was named Principal Policy Director in April 2018. He has served as Acting Deputy Director since July 2018.
CUNA filed a comment letter with the Federal Reserve Board in connection with an advance notice of proposed rulemaking (ANPR) on Regulation D regarding reserve requirements of depository institutions. Specifically, the Board is considering whether to propose amendments to Regulation D to lower the rate of interest paid on excess balances (IOER) maintained at Federal Reserve Banks by eligible institutions that hold a very large proportion of their assets in the form of balances at Reserve Banks. While the specifics of the Board’s ANPR would not impact credit unions, we decided to use the opportunity to urge the Board to consider amending Regulation D to increase the current regulatory limit of six transfers per month from a savings account.
This week, the House will consider H.R. 2578, the National Flood Insurance Program Extension Act of 2019. This legislation would extend the authority of the flood insurance program from May 31 to September 30. The House will also consider H.R. 5, the Equality Act and H.R. 987, the Marketing and Outreach Restoration to Empower Health Education Act of 2019.
The Senate will consider a number of judicial nominations beginning with Michael J. Truncale, of Texas, to be United States District Judge for the Eastern District of Texas.
CUNA wrote to Chairman Clay and Ranking Member Duffy prior to the Subcommittee’s hearing entitled, “A Review of the State of and Barriers to Minority Homeownership.”
In the letter, CUNA explained how the nation’s 5,500 credit unions are unique, member-owned, democratically-controlled, not-for-profit financial cooperatives that currently serve over 115 million members and highlighted that Many of those members are people of color who rely upon their credit union to meet their housing finance needs.
CUNA wrote in support of S. 149, the Stop Senior Scams Act a bill introduced by Senators Bob Casey (D-PA) and Jerry Moran (R-KS). If enacted, this legislation would create a federal advisory council dedicated to combating senior scams.
Financial exploitation is one of the most common forms of elder abuse. CUNA strongly supports the goal of this legislation to help seniors avoid financial exploitation and to encourage responsible decisions regarding financial management.
Attorneys General from 38 states and territories wrote to Congressional Leadership in both chambers supporting the CUNA-backed Secure and Fair Enforcement (SAFE) Banking Act. If enacted, this legislation would allow financial services to cannabis-based businesses in states where it is legal. CUNA, leagues and the American Bankers Association worked with the AG offices across to the country to coordinate the letter.“We request that Congress advance the SAFE Banking Act or similar legislation that would provide a safe harbor for depository institutions that provide a financial product or service to a covered business in a state that has implemented laws and regulations that ensure accountability in the marijuana industry,” the letter reads. “An effective safe harbor would bring billions of dollars into the banking sector, enabling law enforcement; federal, state and local tax agencies; and cannabis regulators in 33 states and several territories to more effectively monitor cannabis businesses and their transactions.
CUNA responded to Senator Bernie Sanders and Representative Alexandria Ocasio-Cortez’s recent proposal to cap the interest rates consumers pay for credit card and other loans that also called for the U.S. Postal Service to start providing more affordable financial services products to consumers.
In the letter CUNA refuted the need for such legislation, detailing why credit unions are the best option for consumers and already provide safe, affordable and quality financial services to local communities.
Membership through a credit union provides a consumer with all the protections that Sanders and Ocasio-Cortez are seeking, including:
The House Financial Services Committee passed H.R. 2514, the “Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform (COUNTER) Act of 2019,” which includes Bank Secrecy Act/Anti-Money Laundering (BSA/AML) relief for credit unions.
Representative Cleaver (D-MO) and Committee Chairwoman Maxine Waters (D-Calif.) worked with Representative Barry Loudermilk (R-Ga.) to add an amendment to H.R. 2514 to index the Currency Transaction Report thresholds for inflation and further study the impact of Suspicious Activity Reports (SARs).
CUNA and state credit union leagues attended a CFPB Town Hall in Philadelphia, Pennsylvania to discuss the CFPB’s recently-issued proposal on debt collection practices under the Fair Dept Collection Practices Act (FDCPA). The panel was moderated by David Silberman, CFPB Associate Director for Research, Markets, and Regulation, and included representatives from debt collection associations, consumer advocates, and public interest attorneys.
In her remarks prior to the panel, Director Kathy Kraninger said the Bureau’s rule is intended to provide “clear rules of the road where consumers know their rights and debt collectors know their limitations.” The Director noted the challenges collectors face when dealing with a statute (FDCPA) that is more than 40 years old. The proposed rule is intended to create standards for the FDCPA’s application to modern technology and provide clarity in areas where clarity was lacking.
Prior to the Committee’s hearing entitled, "Review of the FY 2020 USAID Budget Request," CUNA wrote to Chairman Risch and Ranking Member Menendez in support of funding for the Cooperative Development Program.
Since 1971, WOCCU has offered nearly 300 technical assistance programs around the globe – all while serving the mission of improving lives through credit unions and other cooperative financial institutions. WOCCU’s programs provide education and international networking for the exchange of information and ideas.
CUNA wrote to Chairman McGovern and Ranking Member Cole prior to the Committee’s hearing on H.R. 2157, the Supplemental Appropriations Act of 2019. The Chairwoman of the House Appropriations Committee, Representative Nita Lowey (D-NY), is expected to offer a “Manager’s Amendment” to the bill to extend the expiration of the authority of the National Flood Insurance Program from May 31 to September 30, 2019. CUNA urges the Committee to accept this amendment.
Credit unions play an increasingly important role in the housing finance market and, as a result, have a vested interest in the ongoing stability of the National Flood Insurance Program (NFIP). Many credit union members, throughout the United States, live in communities designated as Special Flood Hazard Areas subject to mandatory flood insurance requirements and many of those same members rely upon the coverage offered under the program to insure against the risk of a natural disaster occurring.
CUNA wrote to Committee leadership urging the Committee and Congress as a whole to address data security in order to provide consumers with data privacy. The best approach on data security and privacy for consumers and business is for Congress to develop a strong privacy law that applies to all businesses and entities that collect, house or otherwise possess information.
CUNA wrote to Chairman Kennedy and Ranking Member Coons prior to the Appropriations Subcommittee’s hearing entitled, “Hearing to review the Fiscal Year 2020 budget requests for the U.S. Federal Communications Commission and the U.S. Federal Trade Commission.” As the Committee considers the FCC’s fiscal budget for the upcoming year, CUNA urges Congress to encourage the FCC to modernize its implementing regulations for the Telephone Consumer Protection Act (TCPA).
CUNA’s letter notes that the rules for contacting consumers are completely different for landlines and mobile phones, and that this distinction is “antiquated and unfair and fails to reflect how the vast majority of consumers communicate today.”
The CFPB issued a proposed rule on debt collection practices under the Fair Debt Collection Practices Act (FDCPA). As expected, the proposed rule appears to only cover FDCPA-covered debt collectors.
According to the Bureau’s release, the proposal would “set clear, bright-line limits on the number of calls debt collectors may place to reach consumers on a weekly basis; clarify how collectors may communicate lawfully using newer technologies, such as voicemails, emails and text messages, that have developed since the FDCPA’s passage in 1977; and require collectors to provide additional information to consumers to help them identify debts and respond to collection attempts.”
In addition to the proposal, the CFPB also released supplemental materials intended to assist entities to understand the proposal, including a Fact Sheet and Flowchart. Comments on the proposed rule will be due 90 days after its publication in the Federal Register.
The proposed rule was released ahead of a CFPB Town Hall on debt collection scheduled to take place tomorrow in Philadelphia, PA. CUNA, the Pennsylvania League, and several local credit unions will be present at the town hall.
The House is expected to consider H.R. 2157, the Supplemental Appropriations Act of 2019 and H.R. 986, the Protecting Americans with Preexisting Conditions Act of 2019. The Chairwoman of the House Appropriations Committee is expected to offer a “manager’s amendment” to the supplemental appropriations bill to extend the expiration of the authority of the National Flood Insurance Program from May 31 to September 30, 2019.
The Senate will resume consideration of Joseph F. Bianco, of New York, to be United States Circuit Judge for the Second Circuit.
Credit union leaders from California and Nevada met with CFPB Director Kathy Kraninger in Los Angeles, CA.
Specific issues discussed include the need for strong Property Assessed Clean Energy (PACE) loan regulations, reconsideration of the CFPB’s Remittance rule coverage and safe harbor threshold, payday lending exemptions and the need for the CFPB to define “abusive” under Unfair, Deceptive or Abusive Acts or Practices (UDAAP).
CUNA submitted comments to the Consumer Financial Protection Bureau in response to their request for input on several aspects of the consumer credit card market, the fourth such review as required by the Credit Card Accountability Responsibility and Disclosure (CARD) Act of 2009.“As the CFPB conducts its review of the credit card market, we urge it to be cognizant that excessive regulatory requirements have the potential to divert credit unions’ resources and attention from meeting their members’ needs,” the letter reads. “The credit unions that offer credit card programs do so as a service to their members.”
CFPB Proposes Higher HMDA Thresholds after Strong CUNA Push
Prior to the Subcommittee on Consumer Protection and Financial Institutions hearing on “Ending Debt Traps in the Payday and Small Dollar Credit Industry,” CUNA wrote to Chairman Meeks and Ranking Member Luetkemeyer regarding the CFPB’s Payday Rule.
In the letter, CUNA wrote about the work credit unions did during the recent Government Shutdown. Credit unions provide the safest and most affordable options for consumers in need of short-term and emergency credit. As a recent example, an estimated 800,000 families across the country faced financial insecurity during the recent federal government shutdown. America's credit unions embodied their structure and mission by ensuring that all impacted members had access to low- or no-interest loans with generous repayment terms.
CUNA joined a number of trade associations in writing to Chairman Doyle and Ranking Member Latta prior to the Subcommittee’s hearing on the problem of illegal automated calls.
The signers of the letter strongly support and share the goal of thwarting unlawful actors that seek to defraud or commit other unlawful acts against consumers. Appropriately tailored efforts are critical to protect consumers from deception and other harm. The also urged the Committee to support the Federal Communications Commission’s unprecedented work to bring enforcement actions against illegal actors, while facilitating the ability of legitimate businesses to place valued and important calls to their customers using modern communications technologies.
CUNA wrote to Chairman Crapo and Ranking Member Brown prior to the Senate Banking Committee hearing entitled, “Guidance, Supervisory Expectations, and the Rule of Law: How do the Banking Agencies Regulate and Supervise Institutions?”
The letter included the recent letter CUNA sent the Consumer Financial Protection Bureau Director Kraninger regarding the Bureau’s supervision of the nation’s not-for-profit credit unions.
CUNA wrote to Chairwoman Beatty and Ranking Member Wagner prior to the House Financial Services Subcommittee on Diversity and Inclusion’s hearing on “Good for the Bottom Line: The Business Case for Diversity and Inclusion.”
In the letter, CUNA highlighted what credit unions do to support and promote diversity and inclusion.
CUNA wrote to Chairman Wicker and Ranking Member Cantwell urging Congress to act to set a federal data privacy standard.
CUNA applauds the committee for taking up the critical issue of data privacy and pledged to work with them to create a strong, national data privacy standard. It should go without saying that any serious data privacy statute should include robust data security requirements that all who hold consumer data must follow. Unfortunately, as we have watched the debate over a federal data privacy standard develop, discussion of security requirements has been virtually nonexistent.
Nevertheless, we do not see any way for a data privacy law to achieve its objectives without a strong security standard that is preemptive of state law and applies to all entities that hold or use consumer data. Simply put: Congress cannot provide consumers with data privacy without addressing data security
CUNA wrote to Chairman Graham and Ranking Member Leahy prior to the hearing to “review the Fiscal Year 2020 funding request and budget justification for the U.S. Agency for International Development.”
In the letter, CUNA wrote that there are over 89,000 credit unions in 117 countries with $2.1 trillion dollars in total assets serving 260 million members. The Credit Union National Association is also a member of the World Council of Credit Unions (WOCCU), which is the leading trade association and development organization for the international credit union movem
CUNA wrote to Chairwoman Waters and Ranking Member McHenry prior to the House Financial Services Committee hearing entitled, “Housing in America: Assessing the Infrastructure Needs of America’s Housing Stock.”
In the letter, CUNA wrote that Credit unions play an increasingly important role in the housing finance market and, as a result, have a vested interest in ensuring an adequate supply of housing stock. Many credit union members, throughout the United States, live in communities where the nation’s housing stock has become more limited and unaffordable.
CUNA wrote to Chairman Inhofe, Chairman Smith, Ranking Member Reed, and Ranking Member Thornberry about concerns regarding the inclusion of any language in the National Defense Authorization Act (NDAA) for fiscal year 2020 that would allow banks rent-free access to military installations. Currently, there is no such language in the FY2020 NDAA. Last year, CUNA and the Defense Credit Union Council successfully fought for similar language to be removed from last year’s NDAA.
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