WASHINGTON (6/21/12)--The Consumer Financial Protection Bureau (CFPB) should "fully understand and minimize the potential implementation and ongoing compliance costs and unintended consequences on credit unions from its potential new regulations,'' the Credit Union National Associaiton (CUNA) wrote in a letter to the agency. CUNA Regulatory Counsel Dennis Tsang recommended that the agency "develop limited, targeted questions'' when the bureau begins collecting information about compliance costs and other effects of regulations.
CUNA has been working diligently since the CFPB began operations last year to ensure that credit unions, which already face substantial regulatory burdens, don't have to deal with additional unnecessary time and financial costs.
The CFPB sought input as part of its rulemaking process. The bureau has direct supervisory authority over financial institutions with assets of more than $10 billion. Other credit unions must comply with the CFPB's rules, but the enforcement is done by the NCUA or their state regulator.
CUNA also suggested that sampling institutions that are representative of the markets affected by the CFPB rulemakings can be more efficient than broader inquiries.
"The agency should utilize proper statistical and research methods to ensure a representative sample for each affected market to properly measure compliance costs," CUNA wrote. "Other institutions that are not part of the sample should have an option to submit their information after reviewing the information collection materials."
Use the resource link to access CUNA full comments.