2012 offers CUs a key opportunity to provide input for regulatory relief

Credit unions have a critical opportunity to offer input for regulatory relief in 2012. With assistance from The League’s Regulatory Advocacy Council and League staff, credit unions can provide input on many issues for which the NCUA, other agencies and the Consumer Financial Protection Bureau (CFPB) have open Comment Calls. It’s credit unions’ chance to influence how they’ll be affected by regulatory decisions concerning loan participation, emergency liquidity and how many regulations might be streamlined as they move under the authority of the CFPB.

The League’s Regulatory Advocacy Council is currently planning on submitting comments to several of the proposed regulatory changes. The Council has asked all Wisconsin credit union presidents for input so that the comment letters that The League submits on behalf of state credit unions address as appropriately and as completely as possible the issues that are important them. Please advise Jo Whiting about what you would like to see included in a comment letter.

By February 7, The League asks for credit unions’ input on:

NCUA’s Loan Participation Rule. The NCUA is proposing several significant changes to its rule. CUNA’s Comment Call explains the key provisions, links to the regulatory language, and shows how the current rules would be altered by the proposed rule change.

Emergency Liquidity. The NCUA has issued an advance notice of proposed rulemaking (ANPR) regarding how credit unions should maintain access to emergency liquidity. The potential new regulation would require all federally-insured credit unions to have access to backup federal liquidity sources in times of financial emergency and distressed economic circumstances. The new regulation, if promulgated, would be added to NCUA's regulation on requirements for share insurance and would apply to both federal and federally-insured state-chartered credit unions. Read CUNA’s Comment Call to learn more.

By February 22, credit unions are also asked to comment on how several rules developed by NCUA, the Fed, HUD and others can be streamlined as they move under the authority of the Consumer Financial Protection Bureau (CFPB). These rules include:

The Consumer Leasing Act (Regulation M)
The Electronic Fund Transfer Act (Regulation E)
The Equal Credit Opportunity Act (Regulation B)
The Fair Credit Reporting Act (Regulation V)
The Fair Debt Collection Practices Act
Sections 502 through 509 of the Gramm-Leach-Bliley Act
(Regulation P; relating to disclosure of consumer personal information)
The Home Mortgage Disclosure Act (Regulation C)
The Real Estate Settlement Procedures Act (HUD’s Regulation X)
The S.A.F.E. Mortgage Licensing Act
The Truth in Lending Act (Regulation Z)
The Truth in Savings Act (Regulation DD)
Section 626 of the Omnibus Appropriations Act of 2009
(relating to unfair and deceptive mortgage lending acts and practices)
The Interstate Land Sales Full Disclosure Act

CUNA’s Comment Call includes a description of areas that CUNA has already flagged for comment as well as specific questions you might consider on these issues.

CUNA is using "Operation Comment" to help credit unions develop their own responses, and we urge you to submit comments from your credit union either by letter or through Operation Comment. However, the impact of individual letters is multiplied by submitting combined comments through The League.

The more specific you can be with your comments, the better – whether about the operational or other challenges and costs posed by a proposal, or any other suggestions.

The League’s Regulatory Advocacy Council, which is helping to coordinate The League’s response on behalf of credit unions statewide, includes Mark Willer of Royal Credit Union, Paul Grinde of CoVantage Credit Union, Anne Heggelund of Marathon County Employees Credit Union, Lisa Greco of AppleTree Credit Union and Jon Lowrey of Dane County Credit Union.

CUNA is working with CUNA, leagues, AACUL's Regulatory Advocacy Advisory Committee, key CUNA Subcommittees, and CUNA Councils to review these issues and gather input on them from credit unions nationwide.

Our article series, Membership Matters, explains additional ways The League and CUNA advocate for credit unions on regulatory and other issues.