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CUNA to CFPB Consider exempting CUs in rulemaking
WASHINGTON (6/4/12)--The Credit Union National Association (CUNA) urged the Consumer Financial Protection Bureau (CFPB) to consider exempting credit unions from agency rulemakings, and to address remittance transfer, overdraft protection and mortgage and mortgage-related regulations as it looks for ways to streamline existing financial rules.

"While the CFPB has been tasked by Congress to implement 18 laws and assume other duties, the agency was also given broad authority to minimize the compliance burdens of its rules on entities such as credit unions…The role of the CFPB in alleviating compliance burdens for institutions that are already heavily regulated is as important as its responsibility to develop and implement regulations for entities that, prior to the establishment of the CFPB, escaped meaningful government oversight," CUNA Deputy General Counsel Mary Dunn said in a Friday comment letter.

The letter focused on concerns in three major areas: remittance transfers, overdraft protection, and mortgage and mortgage-related regulations.

"Since the inception of the CFPB, CUNA has strongly supported the objective of protecting consumers from unscrupulous service providers but credit unions are more concerned than ever that the agency will impose an endless range of new requirements and data collection responsibilities on the most scrupulous service providers in the marketplace: credit unions," the letter said.

CUNA suggested the CFPB could also minimize all reporting requirements under Dodd-Frank, including those regarding gender, minority status, credit scores, points and fees, for smaller institutions.

The CFPB also should do a better job of estimating the amount of funds and resources that credit unions and other institutions will need to dedicate to comply with new rules, CUNA said in its letter. Any new proposals or final regulations should include executive summaries and charts that demonstrate how the proposed changes would impact existing rules. The CFPB should also lay out how its rules have been changed between the proposed and final stages.

Financial institutions should be given the time needed to comply with any regulatory changes that are approved by the CFPB, and the CFPB should clearly delineate between a rule's effective date and any mandatory compliance date(s), CUNA said.

The agency should also create a standard review period for all rulemakings, the letter added.

For the full CUNA comment letter, use the resource link.


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