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CUNA brings CU reg burden and more to CFPB
WASHINGTON (8/25/11)—While Washington has remained quiet for most of August, the Credit Union National Association (CUNA) has continued its work on the regulatory front, meeting this week to discuss the credit union regulatory burden with Consumer Financial Protection Bureau (CFPB) Assistant Director for Community Banks and Credit Unions Elizabeth Vale.
Click to view larger image CFPB Assistant Director for Community Banks and Credit Unions Elizabeth Vale, right, was joined by CUNA Deputy General Counsel Mary Dunn, CFPB Assistant Director for Card Markets David Silberman, and NCUF Executive Director Bucky Sebastian during a Wednesday meeting in Washington. (CUNA photo)
CUNA Deputy General Counsel Mary Dunn, accompanied by National Credit Union Foundation Executive Director Bucky Sebastian, met with Vale and others at the agency’s offices in Washington. During the discussions, they again called on the CFPB to consider ways to help minimize regulatory burden for credit unions. CUNA continues to advocate that the agency establish an Office of Regulatory Burden Monitoring to help track, consider, and mitigate the cumulative regulatory burden under which credit unions and others must operate. Financial literacy, the pending Truth-in-Lending proposal on the ability of the borrower to repay, as well as issues with the Qualified Residential Mortgage (QRM) rule under the credit risk retention proposal were discussed. Regarding the QRM proposal, CUNA has strongly criticized provisions that would set a 20% minimum down payment threshold for mortgages that would be exempt from certain credit risk retention requirements, stating it could create unnecessary barriers for qualified borrowers, limit credit unions' ability to tailor loans to their members' needs, and could potentially make it difficult for small financial institutions like credit unions to make non-QRM loans. CUNA has also criticized the proposed 20% down payment threshold as “too high,” adding that high minimum down payments alone “are not always a significant factor in reducing defaults compared to underwriting and other mortgage product features." CUNA representatives also participated in a call yesterday with the CFPB on its project to combine Truth-in-Lending and Real Estate Settlement Procedures Act mortgage disclosure forms. In this call, the CFPB indicated that it is continuing its efforts to draft the “right” disclosure for consumers, adding that it is the agency’s intent to ensure that consumers can understand the forms and make informed decisions concerning mortgage lending. CFPB representatives indicated that a fourth round of draft disclosure forms will be issued in September, and that additional roundtable calls would be held to further discuss and revise the forms at this time, as well. Vale continues to encourage credit unions to submit comments and concerns regarding these future drafts via the agency’s Web site as the CFPB moves forward with the disclosure revision process, and CUNA plans to remain an active party in this and other CFPB initiatives. CUNA is also working with credit unions to compile a comprehensive list of credit unions' regulatory burdens to send to federal regulators. For more on this regulatory effort, use the resource link.


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