March 1, 2012
Association Responds to NCUA Proposal on Changes to RegFlex Program
The Northwest Credit Union Association (NWCUA) commented on the National Credit Union Administration’s (NCUA’s) recent proposal, which would essentially eliminate the current Regulatory Flexibility program and incorporate some of that relief into the appropriate specific rules.
While expanding the program to credit unions not currently a part of RegFlex is a positive move, the Association urged the NCUA to use caution in not creating more burden for those credit unions that are in the program now. The NWCUA supported the NCUA’s efforts to eliminate restrictions on charitable contributions and to extend the fixed assets rule from three to six years.
“We strongly support the change in the fixed assets rule which would allow FCUs six years, rather than three, to partially occupy unimproved land when acquired for future expansion,” the NWCUA wrote in its comment letter. “The current process, even with a waiver system, is burdensome, and this will provide relief to FCUs which may have acquired land during better economic times or at very good rates.”
However, the Association asked the NCUA to ensure that additional burden was not brought on to credit unions in making these changes.
“The Association appreciates these efforts by NCUA and encourages it to look at ways to simplify credit union regulation and only propose and move forward with regulations that are directly tied to safety and soundness or that would provide significant regulatory relief. Credit unions of all sizes fear the constant onslaught of regulatory change.”
Read the full letter here.
CFPB Looking for Consumer Advisory Board Nominations
The Consumer Financial Protection Bureau (CFPB) is looking for experts to serve on the Consumer Advisory Board. They are seeking board members who have diverse perspectives and innovative ideas in various areas, including consumer financial products and services.
“This is a great opportunity for credit unions to get their voices heard at the highest levels of the CFPB,” said NWCUA Director of Regulatory Advocacy Jaycee Winn. “If you’re interested, we’d be happy to help!”
Read more here.
CFPB Puts Out Single Disclosure for Review
The CFPB has taken the next big step in its efforts to combine the Truth in Lending Act (TILA) and Real Estate Settlement Procedures Act (RESPA) forms… they’ve created one document to comment on.
“Up to this point, it has been more of an A vs. B question,” Winn said. “Here, the CFPB wants to know what you do and don’t like about this form with a goal of using that input to create a regulatory proposal.”
Because it is subject to the Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA), the bureau will be required to convene a small-business panel before rolling out any regulation (such as this) that the CFPB director expects to have a significant impact on a substantial number of small-business entities. The CFPB has outlined the role this panel will play in the disclosure process.
“It should be an interesting process to watch,” Winn said, “as the CFPB is the first financial oversight agency to be subject to SBREFA.”
Review and weigh in on the latest version here.
Read more about CFPB and SBREFA here.
The NWCUA Regulatory Advocacy team works with state and federal regulators to help reduce the regulatory burden on credit unions and protect the credit union movement. The Association encourages members to participate in the regulatory process. If you have any questions on these or any regulatory issues, please contact Director of Regulatory Advocacy Jaycee Winn at firstname.lastname@example.org, or at 800.995.9064 x209.