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Comments on NCUA regs, Freddie/Fannie g-fees due in August
WASHINGTON (7/25/14)--Various regulatory agencies have comment call deadlines during the month of August, on regulations from mortgage guarantee fees to the National Credit Union Administration's annual regulatory review.

The Credit Union National Association will be circulating its draft letters in advance of comment deadlines to credit union leagues and others then submitting detailed comments. CUNA's ongoing concern is to urge all regulators to minimize negative rules and facilitate a more favorable regulatory environment for credit unions.

The due dates and regulations in question are:
  • Aug. 4: NCUA Administration 2014 Regulatory Review. The agency reviews its regulations every three years on a rolling schedule that examines one-third of regulations each year. This year the NCUA will review regulations 748, 749, 750, 760, 761, 790, 791, 792, 793, 794, 796 and 797. CUNA will be recommending a numbers of changes and improvements to NCUA rules;

  • Aug. 4: Freddie Mae and Freddie Mac Guarantee Fees. The Federal Housing Finance Agency announced proposed increases to guarantee fees that Fannie Mae and Freddie Mac charge lenders. The changes include an across-the-board 10 basis point (bp) increase, an adjustment of upfront fees charged to borrowers in different risk categories and elimination of the 25 bp adverse market charge for all but four states. CUNA opposes increases in the g-fees;

  • Aug. 25: NCUA Asset Securitization. The NCUA board would amend regulations to clarify that a natural person federal credit union is authorized to securitize loans that it has originated, as an activity incidental to the business for which the institution is chartered, provided the transaction meets certain requirements. This would also apply to state-chartered credit unions that are permitted by state law to securitize their assets. CUNA supports this proposal and the complementary one below but will be recommending some improvements;

  • Aug. 25: NCUA Safe Harbor. The NCUA board would amend regulations regarding its treatment as liquidating agent or conservator of a federally insured credit union of financial assets transferred by the credit union in connection with a securitization or a participation. The proposed rule continues the safe harbor for financial assets transferred in connection with securitizations and participations in which the financial assets were transferred in compliance with the existing regulation and defines conditions for safe harbor protection for securitizations and participations for which transfers of financial assets would be made after the effective date of this proposed rule; and

  • Aug. 25: NCUA Appraisals. The NCUA would amend the agency's regulations to eliminate the now duplicative requirement that federal credit unions make available a copy of the appraisal used in connection with that member's application for a loan secured by a first lien on a dwelling. The proposed rule would also amend NCUA's appraisal regulations by expanding the current exemption for certain transactions involving an existing extension of credit. CUNA continues to support changes to minimize appraisal requirements.
There are also two comment deadlines coming in September. Comments on the NCUA Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996 are due Sept. 2. Comments on the Consumer Financial Protection Bureau's Mobile Financial Services and their potential for improving financial lives of economically vulnerable citizens are due Sept. 10.

Use the resource links below for information about each comment call.

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