Removing Barriers Blog


  • Consumer Protection 

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 05, 2017 by Ryan Donovan
President Donald Trump signed an executive order focused on the financial system that calls for “efficient, effective and appropriately tailored” regulations. This is a key objective of Credit Union National Association’s Campaign for Common Sense Regulation.
Posted February 02, 2017 by ManojBhoi

The 158-page compliance guide is intended to help financial institutions understand how the rule applies to their operations.

Posted February 02, 2017 by ManojBhoi

The 158-page compliance guide is intended to help financial institutions understand how the rule applies to their operations.

Posted January 29, 2017 by ManojBhoi

On Friday, PHH filed its response to the CFPB’s request for a rehearing en banc in the landmark lawsuit in which the U.S. Court of Appeal for the D.C. Circuit found that the construct of the CFPB violates the constitution and that the Director of it can be removed “at-will”. PHH argued that the court should deny the petition for rehearing en banc.

Posted January 29, 2017 by ManojBhoi

On Friday, PHH filed its response to the CFPB’s request for a rehearing en banc in the landmark lawsuit in which the U.S. Court of Appeal for the D.C. Circuit found that the construct of the CFPB violates the constitution and that the Director of it can be removed “at-will”. PHH argued that the court should deny the petition for rehearing en banc.

Posted January 22, 2017 by ManojBhoi
It was widely reported on Friday that President Trump plans to tap Federal Communications Commission (FCC) Commissioner Ajit Pai to lead the agency in the new Administration.
Posted January 22, 2017 by ManojBhoi
It was widely reported on Friday that President Trump plans to tap Federal Communications Commission (FCC) Commissioner Ajit Pai to lead the agency in the new Administration.
Posted January 22, 2017 by CUNA Advocacy
On the night of the Inauguration the Trump Administration issued a regulatory freeze in a memo from Chief of Staff Reince Priebus to the heads of Executive departments and agencies.
Posted January 05, 2017 by CUNA Advocacy

Prior to consideration in the House of Representatives, CUNA sent a letter to Members of the House urging them to vote for the bill. 

Posted January 03, 2017 by Ryan Donovan

As we have discussed over the last several months, we see a lot of opportunity to advance regulatory reform legislation that improves the operating environment for credit unions to serve their members. 

Posted January 03, 2017 by CUNA Advocacy

The Consumer Financial Protection Bureau’s Office for Older Americans has created a guide called Managing Someone Else’s Money specific to financial caregivers in Illinois.  It is hosting a webinar on January 12 to provide information about it.

Posted December 13, 2016 by CUNA Advocacy

Here's a list of a few issues that may be of interest.

Posted December 12, 2016 by CUNA Advocacy

We sent a letter to the Department of Defense urging them to answer some of our questions. 

Posted December 12, 2016 by CUNA Advocacy

CUNA expressed our ongoing concerns with a proposed Consumer Response Company Response Survey.

Posted December 12, 2016 by Ryan Donovan
A look at our advocacy accomplishments for 2016 and the opportunities that exist in 2017.
Posted December 12, 2016 by CUNA Advocacy

Here are some highlights from the past year. 

Posted December 02, 2016 by CUNA Advocacy

This week, the Consumer Federation of America held its annual Financial Services Conference and credit union advocates were on hand to explain the credit union difference.

Posted October 13, 2016 by CUNA Advocacy

CFPB approves FHFA as a conservator for the Federal Home Loan Mortgage Corporation and the Federal National Mortgage Association. 

Posted October 11, 2016 by CUNA Advocacy
For the last two years or so, we in the CUNA/League system have been talking a lot about “360 Degree Advocacy,” this notion that if public policy issues facing credit unions are addressed from all angles, and resources are brought to bear strategically and deliberately, the likelihood of a successful outcome is increased significantly.  Last week, we saw what 360 Degree Advocacy can do on two key issues – CFPB’s small dollar loan Proposal and NCUA’s supervisory improvement process.
Posted September 30, 2016 by CUNA Advocacy
The last week of Congressional activity before the election featured two significant events relating to credit union priorities.
Posted September 29, 2016 by CUNA Advocacy
Our concerns with the accuracy and privacy of the CFPB consumer complaint database extend to this latest proposal.
Posted September 27, 2016 by CUNA Advocacy
Our letter sent in advance of the hearing, thanked the committee for considering legislation to give NCUA clear authority to provide deposit insurance for prepaid and payroll cards.
Posted September 22, 2016 by CUNA Advocacy
We've used this hearing, and several others, as opportunities to express our many concerns with the outdated TCPA, and the troublesome FCC Order from last year.
Posted September 21, 2016 by CUNA Advocacy
The CFPB has told us that they want to hear directly from credit unions, so we have activated our Grassroots Action Center to make commenting as easy as possible.
Posted September 16, 2016 by CUNA Advocacy
We have been asking both NCUA and the Department of Defense to issue some much-needed clarifications for the MLA rule before it becomes effective.
Posted September 15, 2016 by CUNA Advocacy
In two separate letters, we thanked Senator Mike Rounds (R-SD) for introducing both of these bills, which are Senate companions of the House versions.
Posted September 13, 2016 by CUNA Advocacy
While the bill made it through the committee on mostly partisan lines, its not likely to get a full floor vote during this Congress.
Posted September 13, 2016 by CUNA Advocacy
The over 500-page Dodd-Frank reform bill is set to be considered by the House Financial Services Committee today.
Posted September 12, 2016 by CUNA Advocacy
This month, credit union representatives from many different states are traveling to Washington to have their voices heard, particularly on the proposed small-dollar loan rule from CFPB.
Posted September 12, 2016 by CUNA Advocacy

CFPB highlighted credit unions' work on financial literacy for youth, and released a report entitled " Teaching Financial Fundamentals."

Posted September 09, 2016 by CUNA Advocacy
It appears the Bureau is working separately with first and third party creditors as it writes new debt collection regulations.
Posted September 09, 2016 by CUNA Advocacy
The House Financial Services Committee next week will begin debate on the chairman's Dodd-Frank reform package, which includes several regulatory relief provisions important to credit unions.
Posted August 30, 2016 by CUNA Advocacy
We are seeking comments on the CFPB's proposed changes to its TILA/RESPA Integrated Discolsure (TRID) mortgage rule.
Posted August 25, 2016 by CUNA Advocacy
While we appreciate the release of the compliance guidance document, it may not provide sufficient information in advance of the October 3 effective date.
Posted August 25, 2016 by CUNA Advocacy
Members from both chambers strongly criticized the proposal and urged Director Cordray to amend or re-propose the rule.
Posted August 25, 2016 by CUNA Advocacy

CFPB releases a report on ways to use networks to fight elder financial exploitation and what credit unions can do to join the cause.

Posted August 19, 2016 by CUNA Advocacy
We strongly believe that the recent arbitration proposal from CFPB is inappropriate for credit unions, since they are owned by their members and regularly use consumer-friendly means of dispute resolution.
Posted August 11, 2016 by CUNA Advocacy
In recent meetings, CFPB staff have indicated that the Bureau has no intention to and does not believe it has to use the exemption authority to tailor its regulations toward the abusers of consumers, despite the overwhelming message from Congress.
Posted August 02, 2016 by CUNA Advocacy
This week, the FHFA accepted our concerns regarding language preference on the Uniform Residential Loan Application (URLA)
Posted August 01, 2016 by CUNA Advocacy
This latest change is the result of the FAST Act passed by Congress last year, and further reduces the unnecessary regulatory burdens relating to providing annual privacy notices.
Posted August 01, 2016 by CUNA Advocacy
Although the Bureau was initially hesitant to make changes to the recent TRID rule, we are happy that our requests have led to the release of these proposed fixes.
Posted August 01, 2016 by CUNA Advocacy
While these recent proposals do not include credit unions or first-party collectors, we remain concerned about the Bureau's continued prescriptive approach to rulemaking.
Posted July 29, 2016 by CUNA Advocacy
When you are at the CFPB and someone discloses that the ex parte rules may apply, don’t be intimidated by it.  Rather, embrace it knowing that it means you’re not only going to have your say, but that you are talking to a decision-maker and there will be a record of your conversation.
Posted July 26, 2016 by CUNA Advocacy

CUNA staff met with the Consumer Financial Protection Bureau today to address concerns and seek clarifications about its proposed rule for payday and small dollar loans.

Posted July 26, 2016 by CUNA Advocacy

The Telephone Consumer Protection Act is set for October and CUNA will be challenging this FCC order.

Posted July 22, 2016 by CUNA Advocacy
This will give credit unions more time to assess the impact of the proposed rule.
Posted July 21, 2016 by CUNA Advocacy
Our letter to Director Cordray included many suggestions on how the Bureau could tailor its regulations away from credit unions and towards the actual abusers of consumers.
Posted July 18, 2016 by CUNA Advocacy
The letter echoes a previous message from Congress, which urged the CFPB to expand use of its Section 1022 Exemption Authority.
Posted July 18, 2016 by CUNA Advocacy
We expect the hearing to feature proposals for a regulation on debt collection, however we don't anticipate it to include credit unions at this point.
Posted July 18, 2016 by CUNA Advocacy
While legislators may be out of town for the next several weeks, regulatory activity from the CFPB will continue apace.
Posted July 17, 2016 by CUNA Advocacy
CUNA's views on the Financial CHOICE Act.
Posted July 14, 2016 by CUNA Advocacy
One of the ways to move legislation through Congress is on appropriations bills, two of which currently contain regulatory relief language favorable to credit unions.
Posted July 14, 2016 by CUNA Advocacy
Our President/CEO Jim Nussle testified before the House Financial Services Committee, and answered several questions from Members of Congress about how regulatory burden is impacting the credit union industry.
Posted July 13, 2016 by CUNA Advocacy
The letter raised concerns about possible ECOA and UDAAP issues arising from FHFA's recent proposal.
Posted July 12, 2016 by CUNA Advocacy
Due to our legislative and regulatory advocacy work, this is now the second time CFPB has proposed changes to privacy notices under Regulation P.
Posted July 08, 2016 by CUNA Advocacy
The bill includes funding for important credit union programs and several regulatory relief provisions.
Posted July 06, 2016 by CUNA Advocacy
This CUNA-supported bill sailed through committee and easily passed the whole House by a voice vote.
Posted July 05, 2016 by CUNA Advocacy

Our regulatory advocacy attorneys will walk through our recent analysis of this massive rule, and help credit unions with their comment letters. 

Posted June 27, 2016 by CUNA Advocacy
We have released our summary of the proposed rule, and sent out two letters to regulators highlighting its problems.
Posted June 27, 2016 by CUNA Advocacy
Over the last few months, a number of really positive things have happened as a result of years of advocacy work on the part of CUNA, the Leagues and credit unions.  We all should celebrate these victories!
Posted June 24, 2016 by CUNA Advocacy
The Financial Services Committee Chairman has now made public the details of his Dodd-Frank reform plan.
Posted June 20, 2016 by CUNA Advocacy
The package includes many separate bills that we have supported in the past, and focuses mostly on reducing regulatory burden.
Posted June 18, 2016 by CUNA Advocacy
This extensive report evaluated the recent CFPB proposed rule and the various ways small-dollar lenders have avoided state and federal regulation in the past.
Posted June 17, 2016 by CUNA Advocacy
This reform package is similar to the one recently released by Chairman Hensarling, and specifically focuses on financial services issues.
Posted June 16, 2016 by CUNA Advocacy
The House version of this bill would provide legal immunity and training for financial services employees to report elder financial abuse.
Posted June 14, 2016 by CUNA Advocacy

The Bureau re-affirmed its commitment to publishing proposed fixes to the large and cumbersome TRID rule by late July. 

Posted June 10, 2016 by CUNA Advocacy
While we support the intent of the proposed Playbook, we ask the CFPB to continue to look for ways in which to improve and simplify consumer disclosures.
Posted June 09, 2016 by CUNA Advocacy
The CFPB recently updated its eRegulations platform, which now includes Regulations C, X, and DD.
Posted June 08, 2016 by CUNA Advocacy
This appropriations bill includes several important regulatory relief provisions, including CFPB reforms.
Posted June 07, 2016 by CUNA Advocacy
This package includes several regulatory relief provisions that we have previously supported, including CFPB reforms.
Posted June 06, 2016 by CUNA Advocacy
This reform package could feature up to two-dozen regulatory relief bills for community financial institutions.
Posted June 03, 2016 by DW CMS
Unfortunately, the FCC's narrow reading of the Budget Act led to proposed TCPA exemptions which are virtually meaningless.
Posted June 03, 2016 by DW CMS

The CFPB rule is intended to "coexist" with state laws, but would preempt state law in cases of inconsistency.

Posted June 02, 2016 by CUNA Advocacy
The webinar is intended to assist credit unions as they prepare to comply with the recent expansion of the Military Lending Act (MLA).
Posted June 02, 2016 by CUNA Advocacy
Although we are still analyzing this massive 1300-page rule, so far it has a mixed impact on credit unions.
Posted June 01, 2016 by CUNA Advocacy
We expect this hearing will coincide with the release of the CFPB's much anticipated small-dollar/payday lending proposed rule.
Posted May 27, 2016 by CUNA Advocacy
In the past few months, the CFPB has increasingly focused on preventing elder abuse, and has been distributing media on the subject.
Posted May 24, 2016 by CUNA Advocacy
The draft also maintains or increases funding levels for several important community and small business development funds.
Posted May 24, 2016 by CUNA Advocacy
Pennsylvania credit unions of all different asset sizes discussed regulatory burden,and  urged the CFPB to exempt credit union small-dollar products from the upcoming payday loan rulemaking.
Posted May 24, 2016 by CUNA Advocacy
Two CFPB staff who helped draft the expansion of the rural designation will answer questions during this half-hour briefing.
Posted May 23, 2016 by CUNA Advocacy
We are now welcoming comments from credit unions on the CFPB's recent proposed rule on pre-dispute arbitration clauses.
Posted May 19, 2016 by CUNA Advocacy
Several pending rulemakings will impact credit unions, and could increase the regulatory burdens they face.
Posted May 19, 2016 by CUNA Advocacy
CUNA CEO Jim Nussle and several CUNA staff presented the Director with several documents demonstrating increasing regulatory burden and discussed how the CFPB can ease them going forward.
Posted May 19, 2016 by Meghan M
We believe this recent CFPB proposal could damage the healthy relationship between credit unions and their member-owners.
Posted May 19, 2016 by CUNA Advocacy
We expect that the CFPB's long-awaited proposed rule on payday/small dollar lending will be released at this hearing.
Posted May 18, 2016 by CUNA Advocacy
Committee members and witnesses echoed our concerns, specifically about what constitutes and "autodialer", and what businesses should do when a customer's phone number has been reassigned.
Posted May 18, 2016 by CUNA Advocacy
We are requesting an update to possible revisions of the rule, as well as a compliance guide, before the October effective date.
Posted May 17, 2016 by CUNA Advocacy
Our letter stressed that the CFPB's recent proposed rule on arbitration is not appropriate for credit unions, and could block members' access to timely dispute resolution.
Posted May 12, 2016 by CUNA Advocacy
This latest proposal would create exemptions for calls made to cell phones when collecting a debt owed to or guaranteed by the federal government.
Posted May 10, 2016 by CUNA Advocacy
We are concerned that the upcoming proposal may affect first-party creditors, including credit unions.
Posted May 09, 2016 by CUNA Advocacy
We’re concerned about carve-outs for government debt collectors, and plan to urge the FCC to extend this same exemption to financial institutions.
Posted May 05, 2016 by CUNA Advocacy

We are concerned that this proposal does not take into account the member-centric business model of credit unions, and would remove opportunities for fast, cost-effective dispute resolution.

Posted May 05, 2016 by CUNA Advocacy
These letters expressed concerns that the Bureau has not adequately studied the arbitration issue before proposing its new regulation.
Posted May 03, 2016 by CUNA Advocacy
This final rule amends aspects of the program related to lender indemnification, refinancing, and qualified mortgage requirements.
Posted May 03, 2016 by CUNA Advocacy
This hearing will feature panelists from consumer groups, law firms, and the US Chamber.
Posted May 02, 2016 by CUNA Advocacy
The letter reiterated the importance of credit union small-dollar lending, and asked the CFPB for exemptions from its forthcoming regulation.
Posted April 29, 2016 by CUNA Advocacy
This set of prototype disclosures would provide borrowers with personalized information about their repayment options from loan servicers.
Posted April 29, 2016 by CUNA Advocacy
FFIEC recognizes that the compliance world has changed, and is updating the rule for the first time since 1980, to reflect existing laws and regulations.
Posted April 28, 2016 by CUNA Advocacy
Director Cordray acknowledged the difficulties with the recent TRID rule, and announced that the CFPB will begin the process of amending it.
Posted April 25, 2016 by CUNA Advocacy
CUNA and League representatives discussed successes and challenges with the implementation of HMDA and other recent rules.
Posted April 22, 2016 by CUNA Advocacy
Our letter thanked the Bureau for properly implementing Congress’s intention to expand the pool of small creditors that will be eligible for exemptions from new mortgage rules.
Posted April 21, 2016 by CUNA Advocacy
We expect that the proposed rule for arbitration will be released in conjunction with the hearing.
Posted April 21, 2016 by CUNA Advocacy
This legislation would delay the implementation of the CFPB's HMDA rule until the GAO has studied the impact of these increased data points, and ensured that consumer data remains secure.
Posted April 15, 2016 by CUNA Advocacy
While we appreciate some of the Director's comments, the Bureau has still fallen short of providing meaningful regulatory relief for credit unions.
Posted April 13, 2016 by CUNA Advocacy
The CFPB's structure came under Constitutional scrutiny in recent oral arguments before a US appellate court.
Posted April 13, 2016 by CUNA Advocacy
We urged the CFPB to craft its rulemaking away from credit unions, and acknowledge the consumer-friendly nature of credit union products.
Posted April 12, 2016 by CUNA Advocacy
Credit union staff and representatives met with CFPB officials to clarify and expand on concerns illustrated in our recent comment letter regarding the CFPB's HMDA Resubmission guidelines.
Posted April 11, 2016 by CUNA Advocacy
A CUNA-supported bill that would change the CFPB's funding mechanism is heading to a committee markup on Wednesday.
Posted April 07, 2016 by CUNA Advocacy
The CFPB Director reiterated his view that his agency has appropriately used and interpreted the exemption authority in Section 1022 of Dodd-Frank.
Posted April 07, 2016 by CUNA Advocacy
The Department of Labor released its final rule defining who is a “fiduciary” of an employee benefit plan under the Employee Retirement Income Security Act of 1974 (ERISA).
Posted April 05, 2016 by CUNA Advocacy
The hearing featured expert testimony from four witnesses, and focused on how CFPB enforcement actions and regulations have impacted consumer access to financial services.
Posted April 05, 2016 by CUNA Advocacy
Our letter, which was sent in response to a request for information from two members of Congress, included several suggestions for how the CFPB could ease compliance with this massive new regulation.
Posted April 04, 2016 by CUNA Advocacy
This jointly filed brief urges the Supreme Court to overturn the appellate court's ruling in City of Miami v. Bank of America, which would vastly widen the potential for lawsuits under the Fair Housing Act.
Posted March 29, 2016 by CUNA Advocacy

The CFPB's Final Rule on Prepaid Cards was expected this month, but now the agency is signaling it will be pushed back until May or June. 

Posted March 28, 2016 by CUNA Advocacy
In our response to the Director's recent testimony, we pushed back on his dismissals of the impact of growing regulatory burden.
Posted March 25, 2016 by CUNA Advocacy
The Credit Union Advisory Committee spent the day talking with CFPB staff about existing regulatory burden and upcoming rulemakings.
Posted March 23, 2016 by CUNA Advocacy
These documents included recommendations for how financial institutions can prevent and report financial abuse of American seniors.
Posted March 23, 2016 by CUNA Advocacy
This latest piece of regulatory relief from CFPB was achieved in no small part due to our comprehensive legislative and regulatory advocacy.
Posted March 22, 2016 by CUNA Advocacy
The bill would raise the reporting threshold to 100 closed-end and 200 open-end mortgages.
Posted March 18, 2016 by CUNA Advocacy
We are hopeful that the CFPB won't add additional regulatory burdens on the nascent NCUA Payday Alternative Loan (PAL) Program.
Posted March 18, 2016 by CUNA Advocacy
During this oversight hearing, Director Cordray faced bipartisan questions and concerns about the impacts on community financial institutions from the Bureau's heavy-handed regulatory approach.
Posted March 17, 2016 by CUNA Advocacy
FCC Chair Tom Wheeler included theses new details in a draft Notice of Proposed Rulemaking.
Posted March 17, 2016 by CUNA Advocacy
Our letter express our view that FHFA's oversight role of Fannie/Freddie is to enable and maximize the purchasing and guaranteeing of private market loans.
Posted March 14, 2016 by CUNA Advocacy
Nothing happens in a vacuum.  We did not just wake up one morning and say to ourselves, “Let’s see if we can get Congress to write a letter to the CFPB.”
Posted March 14, 2016 by CUNA Advocacy
An overwhelming bipartisan majority of US representatives sent a letter to CFPB Director Cordray urging him to expand exemptions for credit unions.
Posted March 09, 2016 by CUNA Advocacy
The next Credit Union Advisory Council (CUAC) meeting will be held on March 24, at 3 p.m. at the Consumer Financial Protection Bureau (CFPB). Eight new credit union representatives were appointed to the CUAC this year, including six CUNA members.
Posted March 09, 2016 by CUNA Advocacy
The Consumer Financial Protection Bureau (CFPB) released its latest supervision report today. The report highlights enforcement actions in the student loan market, including illegal automatic defaults by student loan servicers and illegal garnishment threats by debt collectors performing services for
Posted March 06, 2016 by CUNA Advocacy

In his speech before CUNA’s GAC, CFPB Director Cordray also addressed rulemakings which the Bureau is expected to propose this year and next, including overdraft protection and small-dollar lending.

Posted March 06, 2016 by CUNA Advocacy
Cordray said many positive things about the credit union industry in his speech. Going forward we will continue to urge the CFPB to look at the entire picture of how rulemakings are impacting credit unions, particularly small credit unions.  But we disagree with this assessment that the current state of regulatory burden in the marketplace is “good news.”  It is far from that.
Posted March 03, 2016 by CUNA Advocacy
This rulemaking was required under the transportation bill signed into law last December, and clarifies the process for rural institutions to attain regulatory relief.
Posted March 01, 2016 by CUNA Advocacy
Our letter urged Congress to support the bill, and re-iterated the ever-growing compliance burdens facing credit unions since Dodd-Frank.