WASHINGTON (10/1/13)--Credit unions are faced with a short, but very important, list of looming comment deadlines, and the Credit Union National Association's Regulatory Advocacy Report this week urges credit unions to weigh in on each. The topics range from a new charitable accounts rule, to needed bylaw updates, to a proposed definition for "qualified residential mortgage" for purposes of creating an exemption from the risk retention requirements under the Dodd-Frank Act.
Comments are due to CUNA by Oct. 15 and to the National Credit Union Administration no later than Oct. 21 on the agency's plan to allow federal credit unions to invest in charitable donation accounts (CDA), while creating safeguards to ensure the donations are used for their intended charitable purposes.
CUNA generally supports the NCUA proposal and commended the agency for going outside the box to create a novel structure to facilitate the proposed rule. However, CUNA has concerns about a potentially burdensome registration requirement and seeks credit union comment. (Use the first resource link to read a related News Now story.)
The Sept. 30 Regulatory Advocacy Report also reminds credit unions that CUNA is reviewing federal credit union bylaws and welcomes input from credit unions, leagues and others who assist credit unions with these operational rules. The federal credit union bylaws were last updated in 2007 and CUNA anticipates that the NCUA will be updating the "dated" rules soon. (See second resource link for a related News Now story.)
CUNA also urges credit union comment on a proposed credit risk retention regulation, which includes the new QRM definition with modifications that had been urged by CUNA.
Comments on this proposal are due to the Consumer Financial Protection Bureau by Oct. 30 and to CUNA tomorrow.
Under the Dodd-Frank Act, most credit unions would not be directly covered by the QRM proposal. However, CUNA has been weighing in with the various regulators on the QRM issues because there is a concern that the secondary market will conform to QRM standards and that examiners will expect federally insured institutions to meet QRM requirements. (Use the third resource link to read a related News Now story.)
For more on these and other key credit union regulatory topics, CUNA members can use the final resource link below to access the RAR.