Comment Letters

Your comments are put into action in these letters sent by CUNA in response to regulatory proposals.

Listed below are all pending regulations for which CUNA has published a 2014 Comment Letter, regardless of current status. The listed date is the most relevant date for the status that the regulation is in: it could be the CUNA or agency due date, a Comment Letter publish date, or a Final Rule effective date, depending on whether the regulation is currently in the Call, Letter, or Analysis status.

Pending Changes can be sorted by any column in the green bar (Issue, Date, Agency, or Current Status), ascending or descending. For Comment Letters, a current status of "Closed" indicates the Letter has been sent to the agency. All current entries are from 2014, use the "Archive" link at lower left for earlier items.

Issue Date Agency Current Status
Derivatives Investment Authority 07/29/2013 NCUA Open
Capital Planning and Stress Testing – Schedule Shift 03/27/2015 NCUA Closed
Prepaid Accounts 03/23/2015 CFPB Closed
NCUA's Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA) Regulatory Review 03/19/2015 NCUA Closed
Amendments to the 2013 Mortgage Rules under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z) 03/16/2015 CFPB Closed
Submission of Credit Card Agreements under the Truth in Lending Act 03/06/2015 CFPB Closed
Same Day ACH Proposal 02/06/2015 NACHA Closed
Removal of 36-Month Non-Payment Testing Period Rule 01/13/2015 IRS Closed
Proposed Regulation on Federal Home Loan Bank Membership 01/12/2015 FHFA Closed
Proposed Corporate Credit Unions Rule 01/05/2015 NCUA Closed
Proposed Interagency Flood Insurance Rule 12/24/2014 NCUA Closed
Military Lending Act Proposal 12/22/2014 Other Closed
DOD Proposed Rule re Military Lending Act 12/22/2014 Other Closed
Policy on No-Action Letters 12/15/2014 CFPB Closed
Petition to Exempt Time-Sensitive Informational Calls from TCPA Prior Consent Requirements 12/08/2014 Other Closed
2014 Proposed Amendments to TILA/RESPA 11/10/2014 CFPB Closed
FHA 2015 - 2017 Enterprise Housing Goals 10/28/2014 FHFA Closed
NACHA Compliance & Operational Topics 2014 10/24/2014 NACHA Closed
Proposed Single Security Structure 10/13/2014 FHFA Closed
Fixed Assets 10/10/2014 NCUA Closed

Status Key

  • OPEN = CUNA seeking input to prepare comment to agency
  • CLOSED = CUNA comment filed, agency comment period closed
  • FINAL = Agency has issued final ruling