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Influence regulatory changes through comment letters


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 for credit unions to help shape how the law will work in action. Already in 2013, Wisconsin credit unions have weighed in through The League's comment letters 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 comment 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 talking to someone on the Council.

Already this year, The League has weighed in to influence rule changes being made by:


  • The Financial Accounting Standards Board (FASB), concerning credit losses.


  • The Consumer Financial Protection Bureau (CFPB), concerning ability to repay and mortgage servicing.


  • The National Credit Union Administration (NCUA), concerning derivatives


"We believe that the regulatory advocacy in which credit unions are engaging is having an impact on federal agencies," Whiting said.

She explains that in the last year, the NCUA raised the asset level defining a "small" credit union from $30 million to $50 million based on comment letters it received—making more credit unions eligible for assistance from the NCUA—and it also has shelved for reconsideration proposed rules on CUSOs and emergency liquidity requirements.


The CFPB made changes to its proposed mortgage service rule, exempting credit unions that service 5,000 or fewer mortgage loans from providing monthly mortgage statements and informing borrowers of any available loss mitigation options; by the time the rule becomes effective in January 2014, it may include additional exemptions for credit unions. The CFPB has even issued proposed amendments to a couple of its own rules, including the qualified mortgage and ability to repay rules, based on continual feedback from credit unions.


"We'll keep writing letters," Whiting said, "and putting the pressure on the regulators to hear what credit unions are saying about the impact of regulation on their ability to provide good and economical services to their Main Street members."


Don't miss The League's regulatory update webinar on October 8. The League's Legal Affairs staff will explain how the latest regulatory changes are affecting Wisconsin credit unions.

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