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 August 31, 2020 by jbrunson

CUNA filed a letter with FHFA regarding the capitalization framework for Fannie Mae and Freddie Mac.

Posted August 31, 2020 by jbrunson

CUNA filed a letter with NCUA in support of the agency’s efforts to modernize the examination process.

Posted August 28, 2020 by dyi

NCUA's Ask the Regulators webinar, “Basics of PPP Loan Forgiveness and the SBA PPP Loan Forgiveness Platform,” has been rescheduled to September 3.  

Posted August 28, 2020 by dyi

Credit unions can learn more about potential collaborations with NeighborWorks America during an upcoming webinar hosted by the National Credit Union Administration.

Posted August 27, 2020 by dyi

The Federal Housing Finance Agency announced that Fannie Mae and Freddie Mac will extend the moratoriums on single-family foreclosures and real estate owned evictions until at least December 31, 2020.

Posted August 27, 2020 by dyi

The NCUA is looking for comments on their proposed rule that would, for purposes of determining a credit union’s net worth classification under PCA, have them phase-in the day-one adverse effects on regulatory capital that may result from adoption of CECL.

Posted August 25, 2020 by CUNA Advocacy

CUNA, AACUL, and all of the state credit unions Leagues wrote to Director Calabria detailing the impact of the fee and urging a delay of the implementation of the GSE refinance fee.  CUNA had previously written the Director and joined other trades in strong opposition of the fee.

“Credit unions provide consumers with good faith estimates of closing costs, interest rates and other loan terms well in advance of loan closing so they can understand and determine if refinancing will help them reduce monthly payments, pay off high interest debts and/or make a large purchase,” the letter reads. “Unfortunately, the fee’s September 1, 2020, effective date has caused significant disruptions to applications throughout credit union loan pipelines.”

Later in the day, the Federal Housing Finance Agency (FHFA) announced it will delay implementation of its GSE refinance fee until December 1, past the original effective date of September 1. The Agency also announced that Fannie Mae and Freddie Mac will exempt refinance loans with loan balances below $125,000, nearly half of which are comprised of lower income borrowers at or below 80% of area median income. Affordable refinance products, in Fannie Mae’s Home Ready and Freddie Mac’s Home Possible programs, are also exempt.

Posted August 26, 2020 by dyi

The CFPB issued a request for information to assess the impact of the rules on the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act Rules).

Posted August 24, 2020 by dyi

The Federal Reserve System, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, National Credit Union Administration, and the Conference of State Bank Supervisors will host a joint webinar on Thursday, Aug. 27 at 11 a.m. EST on the Small Business Administration’s Paycheck Protection Program Loan Forgiveness Platform.

Posted August 21, 2020 by CUNA Advocacy

CUNA submitted comments in response to the Consumer Financial Protection Bureau’s (CFPB) proposed Advisory Opinion (AO) program that would provide another mechanism through which it may better enable regulatory compliance. The proposed AO Program would allow parties to request interpretive guidance in the form of an AO, to resolve questions regarding regulatory uncertainty.

Posted August 21, 2020 by dyi

The Federal Reserve Board, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network, the National Credit Union Administration, and the Office of the Comptroller of the Currency today issued a joint statement clarifying that Bank Secrecy Act (BSA) due diligence requirements for customers who may be considered "politically exposed persons" (PEPs) should be commensurate with the risks posed by the PEP relationship.

Posted August 20, 2020 by jbrunson

The Bureau issued a request for information (RFI) asking for information to identify opportunities to prevent credit discrimination, encourage responsible innovation, promote fair, equitable, and nondiscriminatory access to credit, address potential regulatory uncertainty, and develop viable solutions to regulatory compliance challenges under the Equal Credit Opportunity Act (ECOA) and Regulation B.

Posted August 20, 2020 by jbrunson

CUNA submitted a comment letter to NCUA regarding the agency’s annual review of one-third of its regulations. We used the opportunity to reiterate ongoing issues as well as raise several new issues with certain regulations.

Posted August 14, 2020 by CUNA Advocacy

CUNA continued its strong opposition to a recently announced Fannie Mae and Freddie Mac fee increase for certain purchased refinanced mortgages. In a letter sent to Federal Housing Finance Agency (FHFA) Director Mark Calabria, a day after CUNA joined a broad a coalition of organizations representing housing, financial services industries as well as public interest groups to issue a statement calling for the fee, scheduled to begin September 1, to be withdrawn.

"This late night, peremptory proclamation by the GSEs threatens to undercut the mortgage market for borrowers who are benefitting from refinancing in an environment of historically low interest rates. Given the serious challenges faced by American families due to the economic impacts of COVID-19 emergency, we are unable to understand why the GSEs would be encouraged or allowed to undermine the mortgage refinancing market, one of the few bright spots in our economy at the moment. Refinanced mortgages can lower payments for borrowers and provide them with liquidity needed to pay off high interest debt, make needed home repairs or provide funds for a purchase. Not only will this decision raise costs for credit union members and other borrowers, it may ultimately price some of our most vulnerable potential homeowners out of the market."

Posted August 14, 2020 by dyi

UNA submitted comments to the CFPB in response to their interim final rule titled, "Treatment of Certain COVID-19 Related Loss Mitigation Options Under the Real Estate Settlement Procedures Act (RESPA)(Reg X)."

Posted August 13, 2020 by jbrunson

CUNA joined a broad coalition of organizations representing the housing, financial services industries as well as public interest groups to issue the following statement on the GSEs’ new adverse market fee.

Posted August 10, 2020 by dyi

CUNA submitted comments to the CFPB in response to their request for comment regarding their interim final rule titled, “Qualified Mortgage (QM) Definition Under the Truth in Lending Act (Regulation Z): Extension of Sunset Date.” 

Posted August 10, 2020 by dyi

CUNA expressed support for the Department’s goal of protecting workers and retirees and provided several recommendations for the Department to consider prior to finalizing the proposed exemption.

Posted August 05, 2020 by CUNA Advocacy

CUNA continued its strong push to include Paycheck Protection Program (PPP) forgiveness language in the next phase of pandemic relief legislation by updating the action alert calling on credit unions and small business to support the bill.

There are bipartisan Senate and House bills offering simplified forgiveness of PPP loans under $150,000 that credit unions are advocating for inclusion as Congress continues negotiations on COVID-19 relief legislation.

The bills would also ensure a lender will be held harmless from any enforcement action if the borrower’s attestation contained falsehoods.

In addition to reaching out to members of Congress urging them to support inclusion, CUNA is also asking credit unions to activate their members to share with Congress the importance of having the PPP loans forgiven.  

Posted August 05, 2020 by CUNA Advocacy

The Senate Banking Committee advanced Kyle Hauptman's nomination by a voice vote this afternoon.  Mr. Hauptman's nomination for the NCUA Board will now go to the full Senate floor for a vote.  

CUNA historically does not take positions on presidential nominations, but submitted a letter for the hearing featuring Hauptman’s testimony commending NCUA’s recent actions and hoping any future nominee will build on that momentum.

Posted August 04, 2020 by CUNA Advocacy

CUNA submitted comments to the CFPB in response to their notice of proposed rulemaking amending Regulation F, which implements the Fair Debt Collection Practices Act (FDCPA). The proposal would amend Regulation F to require debt collectors to make certain disclosures when collecting time-barred debts (debts for which the applicable statute of limitations has expired).

“We respectfully recommend the Bureau continue to rely solely on its Fair Debt Collection Practices Act (FDCPA) authority when promulgating rules governing the practice of debt collection,” the letter reads. “The FDCPA provides the Bureau with ample ability to achieve its desired limitations on third-party collections without exposing credit unions that collect their own debts to expanded regulatory compliance and litigation burden.”

Posted August 04, 2020 by CUNA Advocacy

Senator Brian Schatz (D-HI) introduced legislation that would create a $2 billion Community Development Institutions (CDFI) crisis fund to help with pandemic recovery.  CUNA wrote to the Senator in support of his legislation the day it was introduced.

“The pandemic and ensuing economic crisis has had a disproportionate impact on vulnerable communities and the policy response needs to recognize that more needs to be done to help these communities recover,” Nussle said. “Sen. Schatz’s legislation to create a CDFI Crisis Fund will ensure that CDFI credit unions can get much needed resources to our most vulnerable communities, reducing the pain experienced as the result of any number of disasters.” 

Posted August 04, 2020 by CUNA Advocacy

CUNA wrote to Representatives Houlahan (D-PA) and Upton (R-MI) in support of H.R. 7777, legislation “To provide automatic forgiveness for paycheck protection program loans under $150,000, and for other purposes.”

If enacted, H.R. 7777 would provide forgiveness for Paycheck Protection Program (PPP) loans of $150,000 or less if the borrower submits an attestation form to the lender. It also ensures that the lender will be held harmless from any enforcement action if the borrower’s attestation contained falsehoods.

America’s credit unions have issued thousands of PPP loans to help small business owners recover from the impact of the pandemic. For the country’s smallest credit unions, that amounts to over 60,000 loans averaging just $49,000—a true measure of just how crucial this program has been to the mom and pop organizations that keep Main Street resilient.

Posted August 04, 2020 by CUNA Advocacy

CUNA wrote to the Consumer Financial Protection Bureau to express appreciation for the proactive effort to amend Regulation Z to facilitate the LIBOR transition for consumer financial products in response to LIBOR’s planned discontinuation after 2021. Currently, LIBOR is expected to be discontinued sometime after 2021 and the CFPB intends for a final rule on LIBOR to take effect on March 15, 2021 (except for certain change-in-term requirements for credit cards and home equity lines of credit.)

“CUNA generally supports the Bureau’s proposal and believes clarity of compliance expectations surrounding the LIBOR discontinuation is beneficial for financial institutions and, ultimately, consumers.”

Posted August 03, 2020 by CUNA Advocacy

CUNA submitted comments to the Office of the Comptroller of the Currency in response to the advance notice of proposed rulemaking regarding national bank and federal savings associations’ digital activities. We are concerned that the Office of the Comptroller of the Currency is considering “industry altering changes” without sufficient public consideration.

Although Acting Comptroller Brooks in his comments mentions that this charter will have a narrow focus within the Comptroller’s authority, we are concerned chartering such a special purpose bank represents a significant policy change at the OCC that should only be done after careful consideration and public rulemaking so that public policy and the public’s interests can be thoroughly considered,” CUNA wrote.

Posted August 02, 2020 by CUNA Advocacy

The Senate will convene at 3:00 pm today to resume consideration of Mark Wesley Menezes to be Deputy Secretary of Energy. 

The House of Representatives in not in session this week.

Posted July 31, 2020 by CUNA Advocacy

Credit unions, CUNA and state credit union leagues met with Senator Kevin Cramer (R-ND) on Friday afternoon to discuss credit union involvement in the Paycheck Protection Program (PPP) and his proposed bill to forgive most PPP loans. Senator Cramer is the lead sponsor of the bipartisan S. 4117, the Paycheck Protection Small Business Forgiveness Act, which would make PPP loan forgiveness easier for loans under $150,000 and provide lenders with liability protection. The conversation was held through a web meeting hosted by CUNA.  

“Here in the Dakotas, credit unions really stepped up in the PPP process, as a third of our credit unions were involved in that and Senator Cramer is a longtime friend of the credit unions,” Jeff Olson, President/CEO of the Credit Union Association of the Dakotas, said during his introduction of the Senator.