WASHINGTON (2/23/12)--Although the Consumer Financial Protection Bureau's (CFPB) interim final rule implementing the Equal Credit Opportunity Act substantially duplicates the Federal Reserve Board's Regulation B, the few changes suggested by the bureau could impose unnecessary reporting burdens on credit unions, the Credit Union National Association (CUNA) warned the bureau.
The interim final rule was issued as part of the CFPB's ongoing project of requesting comment on how to streamline the regulations that were transferred to its authority from other agencies under the Dodd-Frank Wall Street Reform and Consumer Protection Act.
In supplementary information accompanying the CFPB's request for comments, the bureau noted there are some changes to Reg B required by the Dodd-Frank Act. They are, according to the CFPB, needed to implement small business loan data collection requirements, as well as the right of consumers to be provided a copy of an appraisal.
CUNA urged the CFPB to do all it can to minimize the impact of any new reporting requirements on credit unions. Also, CUNA recommended that the CFPB coordinate with the Fed to insure motor vehicle dealers are subject to the same data collection requirements as traditional depository institutions.
The supplementary information also said the CFPB may increase the duration of a record-keeping requirement. The change would recognize that Dodd-Frank expands a statute of limitations under Reg B from two to five years for filing civil actions, such as when a borrower or potential borrower files suit against a lender under the regulation.
"In recognition of the regulatory burdens that credit unions must already operate under, CUNA urges the CFPB to refrain from extending the recordkeeping requirements," CUNA wrote.
Use the resource link to read CUNA's complete comment letter.