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Credit unions remove barriers via the comment process


Influencing legislation isn’t the only way credit unions can shape the environment in which they operate. After laws are passed, agencies write regulations spelling out how laws will be implemented and enforced. This regulatory drafting process offers a precious window of opportunity to help shape how the law will work in action. Over the past year, Wisconsin credit unions have weighed in through The League and CUNA on several key regulatory changes that affect how credit unions operate and serve their 2.4 million members.


The League works in concert with its Regulatory Advocacy Council to offer input to state and federal agencies’ calls for comments when regulations are being written or revised. While credit unions can offer their insights directly to the agencies, The League prepares comment letters that factor in the viewpoints credit unions have shared with us. Sharing insights can be as simple as emailing Jo Whiting, The League’s EVP/Chief Advocacy Officer, or Paul Guttormsson, Regulatory Counsel, or talking to someone on the Council.


League Regulatory Counsel Paul Guttormsson explains how the united CUNA/League system works together to minimize regulatory burden and preserve quality service to credit union members by influencing the regulatory comment process.


Topics that have been addressed in comment letters include:











Did you know?

Each year, the National Credit Union Administration (NCUA) reviews one-third of its regulations and encourages credit unions to provide input on improvements.


In 2014, the agency will review, in part:


  • Records preservation
  • Loans in flood hazard areas
  • Bank Secrecy Act compliance
  • Tort claims against the government


Read the complete list.









"Credit unions’ participation in the comment process strongly affects outcome on regulatory issues," said Jo Whiting.

She points to the more than 2,000 letters that credit unions submitted solely on the National Credit Union Administration’s Risk-Based Capital proposal.


Subsequent to credit unions’ massive outpouring of feedback, the agency says it is revisiting the proposal’s risk weights, specific treatment of business loans for risk-weighting, the definition of a complex credit union, examiner discretion on raising an individual credit union’s required capital level, and the timing for compliance with the final rule, among other issues.


Credit union feedback has influenced a host of other issues, as well.


"We have to keep explaining to regulators the real consequences of regulations on credit unions’ ability to provide the service that keeps families and communities strong," Whiting adds. "Members count on us to ensure that service is not diminished as part of this process, which is why taking regulatory action is cited in credit unions’ nationwide strategy to become Americans’ best financial partner."


CUNA and The League work in concert with credit union Activists year-round to communicate about credit unions’ mission and advocate for legislative and regulatory improvements to credit unions’ operating environment.


Visit CUNA’s website for more resources to aid your regulatory advocacy.


Questions? Contact Jo Whiting at (262) 408-6044 or Paul Guttormsson at (262) 408-6009.




The Unite for Good effort is an internal growth strategy developed by CUNA in conjunction with its Board, state leagues, credit unions and system partners. The plan's action steps – to remove barriers, increase awareness and foster service excellence–are aimed at helping more credit unions become their members' primary financial institution by compelling members to see credit unions as their best financial partner. Read more articles in our Unite for Good series.

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