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Income and expense are whole-filing amounts associated with this lobbyist, not personal compensation or an allocated share.
No topic inference: each bill number appears in source LDA issue text assigned to this lobbyist.
Access to Credit for Small Businesses Impacted by the COVID–19 Crisis Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Specific issues are shown only where the LDA source assigned them to this lobbyist. Targets apply to the associated filing.
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Source: Senate LDA
Access to Credit for Small Businesses Impacted by the COVID–19 Crisis Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Access to Credit for Small Businesses Impacted by the COVID–19 Crisis Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Access to Credit for Small Businesses Impacted by the COVID–19 Crisis Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
SAFE Banking Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
SAFE Banking Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
SAFE Banking Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
SAFE Banking Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Credit Union Governance Modernization Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Credit Union Governance Modernization Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Credit Union Governance Modernization Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Credit Union Governance Modernization Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Postal Service Reform Act of 2022
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Postal Service Reform Act of 2022
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Postal Service Reform Act of 2022
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Postal Service Reform Act of 2022
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Federal Home Loan Banks’ Mission Implementation Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Federal Home Loan Banks’ Mission Implementation Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Federal Home Loan Banks’ Mission Implementation Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Federal Home Loan Banks’ Mission Implementation Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Member Business Loan Expansion Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Member Business Loan Expansion Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Member Business Loan Expansion Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Member Business Loan Expansion Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Expanding Financial Access for Underserved Communities Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Expanding Financial Access for Underserved Communities Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Expanding Financial Access for Underserved Communities Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Expanding Financial Access for Underserved Communities Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Transparency in CFPB Cost-Benefit Analysis Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Transparency in CFPB Cost-Benefit Analysis Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Transparency in CFPB Cost-Benefit Analysis Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Transparency in CFPB Cost-Benefit Analysis Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
FAIR Act of 2022
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
FAIR Act of 2022
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
FAIR Act of 2022
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
FAIR Act of 2022
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Federal Home Loan Banks' Mission Implementation Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Federal Home Loan Banks' Mission Implementation Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Federal Home Loan Banks' Mission Implementation Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Federal Home Loan Banks' Mission Implementation Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
CDFI Bond Guarantee Program Improvement Act of 2022
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
CDFI Bond Guarantee Program Improvement Act of 2022
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
CDFI Bond Guarantee Program Improvement Act of 2022
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
CDFI Bond Guarantee Program Improvement Act of 2022
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
TAILOR Act of 2022
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
TAILOR Act of 2022
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
TAILOR Act of 2022
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
TAILOR Act of 2022
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Small LENDER Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Small LENDER Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Small LENDER Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Small LENDER Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Expanding Access to Lending Options Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Expanding Access to Lending Options Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Expanding Access to Lending Options Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Expanding Access to Lending Options Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
SAFE Banking Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
SAFE Banking Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
SAFE Banking Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
SAFE Banking Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders".
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions
Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders".
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions
American Rescue Plan Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance; H.R. 133, the Consolidated Appropriations Act of 2021; support efforts to correct gaps in BSA/AML regulations and CVC reporting; urges FinCEN to allow for additional time for stakeholder comments and providing a reasonable implementation period for new requirements; support CDCs recommendation that workers in the finance industry be included as essential workers; support dedicated cash window to include all credit unions; support communication on relevant information regarding the First and Second Draw PPP loans; supports HUDs proposal to amend the FHAs regulations to allow borrowers of single-family properties and other insured properties the option to purchase private flood insurance on FHA-insured mortgages for properties located in Special Flood Hazard Areas (SFHAs) to satisfy the mandatory purchase requirements of the Flood Disaster Protection Act of 1973; support additional investment authorities for credit unions to manage this influx of deposits; support access to credit for small businesses impacted by the COVID-19; support loan maturity extension; FCU Act should allow all credit unions to add underserved areas to their fields of membership; support ESIGN Modernization; expand section 4016 of the CARES Act; parity for credit unions for protections under section 4008 of the CARES Act; expand section 4014 of the CARES Act; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; caution you against making major changes to bankruptcy law; NCUA should (1) immediately issue an interim final rule to provide credit unions parity with recent changes made to community bank threshold standards or offer a different evaluation of credit union assets; and (2) coordinate with the CFPB to provide uniformity in the calculation of credit union assets for purposes of the $10 billion threshold; support efforts to provide flexibility for FCUs to operate their mortgage loan businesses and provide FICUs with another avenue to sell their mortgage servicing rights; support proposed rule to remove the prohibition on the capitalization of interest under Appendix B to Part 741; support authorization of a second PPP loan, simplifying loan forgiveness for PPP loans under the $150,000 threshold and repealing the deduction of EIDL advances from the PPP loan forgiveness amount; Consumer Access to Financial Records; RIN: 3170-AA78; avoid implementing section 1033 in a way that impairs a credit unions ability to protect its members data from the risk of theft or abuse; support update to Chartering and Field of Membership and Shared Facility Requirements, support modernization of the Manual by including online and mobile banking platforms in the definition of service facility; Exempt credit unions from the CECL standard; support proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy; urge the SBA to reduce loan forgiveness review times, focus reviews on larger and riskier loans, and provide consistent processing; opposes any premium that is the direct result of excess share growth rather than material weakness in the Share insurance fund because year-end financials of the SIF reflect the overall strength of the fund; support targeted efforts to help small businesses in these trying times, especially minority- and women-owned businesses that have struggled to access funding; support Homeowner Assistance Fund bill; Ensure that there is a liability shield for businesses that follow the law, protect their employees; raise concerns about legislatively mandated blanket loan forbearance; supports the NCUA having express authority to exempt federally-insured credit unions (FICUs) from suspicious activity report (SAR) requirements; support the FHFAs acknowledgement of the need to modernize appraisals by creating a more streamlined and accurate valuation process, requests that the FHFA require consistent practices among individual appraisers; continue to allow Automated Valuation Models (AVMs) and appraisal waivers to be used for all low-risk mortgage loans; and update the AVM technology to allow AVMs to be used in rural areas to improve appraisal turnaround times; H.R. 1319, the American Rescue Plan Act of 2021; Provide temporary capital flexibility for the National Credit Union Administration (NCUA) and credit unions, such as a reduction in the level at which credit unions are considered well capitalized; Urges Support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; support relief from the member business loan (MBL) cap; requests that the NCUA consolidate its supervisory guidance into fewer letterheads, improve its website to increase usability, and release timely cybersecurity risk alerts; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; support allowing the GSEs to rebuild capital and ensuring the GSEs are in a safe and sound financial condition before exiting conservatorship to guarantee a healthy and sustainable secondary mortgage market; ensure that any incentives for excessive risk-taking are eliminated but the FHFA should be encouraging the GSEs to focus on increasing opportunities for very-low, low-, and moderate income individuals to purchase a home; support Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act (Economic Aid Act) as part of the year-end stimulus package; support expansion for SBA Interim Final Rule that implements a revised PPP loan calculation formula for Schedule C filers; reject and urge against pilot program for USPS postal banking; support American Rescue Plan Act assistance; exclude credit union member business loans made in response to COVID-19 relief from the credit union member business lending (MBL) cap; urge the Bureau to initiate a rulemaking and exercise its supervisory authority over fintech companies that fall within the scope of a larger participant in the consumer financial services market; urge CFPB to coordinate with the FHFA as it examines its authority to regulate and supervise non-bank mortgage companies; Risk-Based Net Worth-COVID-19 Regulatory Relief; reject ICBAs ongoing attacks on the credit unions; support bank-credit union mergers.
American Rescue Plan Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance; H.R. 133, the Consolidated Appropriations Act of 2021; support efforts to correct gaps in BSA/AML regulations and CVC reporting; urges FinCEN to allow for additional time for stakeholder comments and providing a reasonable implementation period for new requirements; support CDCs recommendation that workers in the finance industry be included as essential workers; support dedicated cash window to include all credit unions; support communication on relevant information regarding the First and Second Draw PPP loans; supports HUDs proposal to amend the FHAs regulations to allow borrowers of single-family properties and other insured properties the option to purchase private flood insurance on FHA-insured mortgages for properties located in Special Flood Hazard Areas (SFHAs) to satisfy the mandatory purchase requirements of the Flood Disaster Protection Act of 1973; support additional investment authorities for credit unions to manage this influx of deposits; support access to credit for small businesses impacted by the COVID-19; support loan maturity extension; FCU Act should allow all credit unions to add underserved areas to their fields of membership; support ESIGN Modernization; expand section 4016 of the CARES Act; parity for credit unions for protections under section 4008 of the CARES Act; expand section 4014 of the CARES Act; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; caution you against making major changes to bankruptcy law; NCUA should (1) immediately issue an interim final rule to provide credit unions parity with recent changes made to community bank threshold standards or offer a different evaluation of credit union assets; and (2) coordinate with the CFPB to provide uniformity in the calculation of credit union assets for purposes of the $10 billion threshold; support efforts to provide flexibility for FCUs to operate their mortgage loan businesses and provide FICUs with another avenue to sell their mortgage servicing rights; support proposed rule to remove the prohibition on the capitalization of interest under Appendix B to Part 741; support authorization of a second PPP loan, simplifying loan forgiveness for PPP loans under the $150,000 threshold and repealing the deduction of EIDL advances from the PPP loan forgiveness amount; Consumer Access to Financial Records; RIN: 3170-AA78; avoid implementing section 1033 in a way that impairs a credit unions ability to protect its members data from the risk of theft or abuse; support update to Chartering and Field of Membership and Shared Facility Requirements, support modernization of the Manual by including online and mobile banking platforms in the definition of service facility; Exempt credit unions from the CECL standard; support proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy; urge the SBA to reduce loan forgiveness review times, focus reviews on larger and riskier loans, and provide consistent processing; opposes any premium that is the direct result of excess share growth rather than material weakness in the Share insurance fund because year-end financials of the SIF reflect the overall strength of the fund; support targeted efforts to help small businesses in these trying times, especially minority- and women-owned businesses that have struggled to access funding; support Homeowner Assistance Fund bill; Ensure that there is a liability shield for businesses that follow the law, protect their employees; raise concerns about legislatively mandated blanket loan forbearance; supports the NCUA having express authority to exempt federally-insured credit unions (FICUs) from suspicious activity report (SAR) requirements; support the FHFAs acknowledgement of the need to modernize appraisals by creating a more streamlined and accurate valuation process, requests that the FHFA require consistent practices among individual appraisers; continue to allow Automated Valuation Models (AVMs) and appraisal waivers to be used for all low-risk mortgage loans; and update the AVM technology to allow AVMs to be used in rural areas to improve appraisal turnaround times; H.R. 1319, the American Rescue Plan Act of 2021; Provide temporary capital flexibility for the National Credit Union Administration (NCUA) and credit unions, such as a reduction in the level at which credit unions are considered well capitalized; Urges Support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; support relief from the member business loan (MBL) cap; requests that the NCUA consolidate its supervisory guidance into fewer letterheads, improve its website to increase usability, and release timely cybersecurity risk alerts; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; support allowing the GSEs to rebuild capital and ensuring the GSEs are in a safe and sound financial condition before exiting conservatorship to guarantee a healthy and sustainable secondary mortgage market; ensure that any incentives for excessive risk-taking are eliminated but the FHFA should be encouraging the GSEs to focus on increasing opportunities for very-low, low-, and moderate income individuals to purchase a home; support Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act (Economic Aid Act) as part of the year-end stimulus package; support expansion for SBA Interim Final Rule that implements a revised PPP loan calculation formula for Schedule C filers; reject and urge against pilot program for USPS postal banking; support American Rescue Plan Act assistance; exclude credit union member business loans made in response to COVID-19 relief from the credit union member business lending (MBL) cap; urge the Bureau to initiate a rulemaking and exercise its supervisory authority over fintech companies that fall within the scope of a larger participant in the consumer financial services market; urge CFPB to coordinate with the FHFA as it examines its authority to regulate and supervise non-bank mortgage companies; Risk-Based Net Worth-COVID-19 Regulatory Relief; reject ICBAs ongoing attacks on the credit unions; support bank-credit union mergers.
David’s Law
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance; H.R. 133, the Consolidated Appropriations Act of 2021; support efforts to correct gaps in BSA/AML regulations and CVC reporting; urges FinCEN to allow for additional time for stakeholder comments and providing a reasonable implementation period for new requirements; support CDCs recommendation that workers in the finance industry be included as essential workers; support dedicated cash window to include all credit unions; support communication on relevant information regarding the First and Second Draw PPP loans; supports HUDs proposal to amend the FHAs regulations to allow borrowers of single-family properties and other insured properties the option to purchase private flood insurance on FHA-insured mortgages for properties located in Special Flood Hazard Areas (SFHAs) to satisfy the mandatory purchase requirements of the Flood Disaster Protection Act of 1973; support additional investment authorities for credit unions to manage this influx of deposits; support access to credit for small businesses impacted by the COVID-19; support loan maturity extension; FCU Act should allow all credit unions to add underserved areas to their fields of membership; support ESIGN Modernization; expand section 4016 of the CARES Act; parity for credit unions for protections under section 4008 of the CARES Act; expand section 4014 of the CARES Act; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; caution you against making major changes to bankruptcy law; NCUA should (1) immediately issue an interim final rule to provide credit unions parity with recent changes made to community bank threshold standards or offer a different evaluation of credit union assets; and (2) coordinate with the CFPB to provide uniformity in the calculation of credit union assets for purposes of the $10 billion threshold; support efforts to provide flexibility for FCUs to operate their mortgage loan businesses and provide FICUs with another avenue to sell their mortgage servicing rights; support proposed rule to remove the prohibition on the capitalization of interest under Appendix B to Part 741; support authorization of a second PPP loan, simplifying loan forgiveness for PPP loans under the $150,000 threshold and repealing the deduction of EIDL advances from the PPP loan forgiveness amount; Consumer Access to Financial Records; RIN: 3170-AA78; avoid implementing section 1033 in a way that impairs a credit unions ability to protect its members data from the risk of theft or abuse; support update to Chartering and Field of Membership and Shared Facility Requirements, support modernization of the Manual by including online and mobile banking platforms in the definition of service facility; Exempt credit unions from the CECL standard; support proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy; urge the SBA to reduce loan forgiveness review times, focus reviews on larger and riskier loans, and provide consistent processing; opposes any premium that is the direct result of excess share growth rather than material weakness in the Share insurance fund because year-end financials of the SIF reflect the overall strength of the fund; support targeted efforts to help small businesses in these trying times, especially minority- and women-owned businesses that have struggled to access funding; support Homeowner Assistance Fund bill; Ensure that there is a liability shield for businesses that follow the law, protect their employees; raise concerns about legislatively mandated blanket loan forbearance; supports the NCUA having express authority to exempt federally-insured credit unions (FICUs) from suspicious activity report (SAR) requirements; support the FHFAs acknowledgement of the need to modernize appraisals by creating a more streamlined and accurate valuation process, requests that the FHFA require consistent practices among individual appraisers; continue to allow Automated Valuation Models (AVMs) and appraisal waivers to be used for all low-risk mortgage loans; and update the AVM technology to allow AVMs to be used in rural areas to improve appraisal turnaround times; H.R. 1319, the American Rescue Plan Act of 2021; Provide temporary capital flexibility for the National Credit Union Administration (NCUA) and credit unions, such as a reduction in the level at which credit unions are considered well capitalized; Urges Support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; support relief from the member business loan (MBL) cap; requests that the NCUA consolidate its supervisory guidance into fewer letterheads, improve its website to increase usability, and release timely cybersecurity risk alerts; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; support allowing the GSEs to rebuild capital and ensuring the GSEs are in a safe and sound financial condition before exiting conservatorship to guarantee a healthy and sustainable secondary mortgage market; ensure that any incentives for excessive risk-taking are eliminated but the FHFA should be encouraging the GSEs to focus on increasing opportunities for very-low, low-, and moderate income individuals to purchase a home; support Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act (Economic Aid Act) as part of the year-end stimulus package; support expansion for SBA Interim Final Rule that implements a revised PPP loan calculation formula for Schedule C filers; reject and urge against pilot program for USPS postal banking; support American Rescue Plan Act assistance; exclude credit union member business loans made in response to COVID-19 relief from the credit union member business lending (MBL) cap; urge the Bureau to initiate a rulemaking and exercise its supervisory authority over fintech companies that fall within the scope of a larger participant in the consumer financial services market; urge CFPB to coordinate with the FHFA as it examines its authority to regulate and supervise non-bank mortgage companies; Risk-Based Net Worth-COVID-19 Regulatory Relief; reject ICBAs ongoing attacks on the credit unions; support bank-credit union mergers.
David’s Law
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance; H.R. 133, the Consolidated Appropriations Act of 2021; support efforts to correct gaps in BSA/AML regulations and CVC reporting; urges FinCEN to allow for additional time for stakeholder comments and providing a reasonable implementation period for new requirements; support CDCs recommendation that workers in the finance industry be included as essential workers; support dedicated cash window to include all credit unions; support communication on relevant information regarding the First and Second Draw PPP loans; supports HUDs proposal to amend the FHAs regulations to allow borrowers of single-family properties and other insured properties the option to purchase private flood insurance on FHA-insured mortgages for properties located in Special Flood Hazard Areas (SFHAs) to satisfy the mandatory purchase requirements of the Flood Disaster Protection Act of 1973; support additional investment authorities for credit unions to manage this influx of deposits; support access to credit for small businesses impacted by the COVID-19; support loan maturity extension; FCU Act should allow all credit unions to add underserved areas to their fields of membership; support ESIGN Modernization; expand section 4016 of the CARES Act; parity for credit unions for protections under section 4008 of the CARES Act; expand section 4014 of the CARES Act; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; caution you against making major changes to bankruptcy law; NCUA should (1) immediately issue an interim final rule to provide credit unions parity with recent changes made to community bank threshold standards or offer a different evaluation of credit union assets; and (2) coordinate with the CFPB to provide uniformity in the calculation of credit union assets for purposes of the $10 billion threshold; support efforts to provide flexibility for FCUs to operate their mortgage loan businesses and provide FICUs with another avenue to sell their mortgage servicing rights; support proposed rule to remove the prohibition on the capitalization of interest under Appendix B to Part 741; support authorization of a second PPP loan, simplifying loan forgiveness for PPP loans under the $150,000 threshold and repealing the deduction of EIDL advances from the PPP loan forgiveness amount; Consumer Access to Financial Records; RIN: 3170-AA78; avoid implementing section 1033 in a way that impairs a credit unions ability to protect its members data from the risk of theft or abuse; support update to Chartering and Field of Membership and Shared Facility Requirements, support modernization of the Manual by including online and mobile banking platforms in the definition of service facility; Exempt credit unions from the CECL standard; support proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy; urge the SBA to reduce loan forgiveness review times, focus reviews on larger and riskier loans, and provide consistent processing; opposes any premium that is the direct result of excess share growth rather than material weakness in the Share insurance fund because year-end financials of the SIF reflect the overall strength of the fund; support targeted efforts to help small businesses in these trying times, especially minority- and women-owned businesses that have struggled to access funding; support Homeowner Assistance Fund bill; Ensure that there is a liability shield for businesses that follow the law, protect their employees; raise concerns about legislatively mandated blanket loan forbearance; supports the NCUA having express authority to exempt federally-insured credit unions (FICUs) from suspicious activity report (SAR) requirements; support the FHFAs acknowledgement of the need to modernize appraisals by creating a more streamlined and accurate valuation process, requests that the FHFA require consistent practices among individual appraisers; continue to allow Automated Valuation Models (AVMs) and appraisal waivers to be used for all low-risk mortgage loans; and update the AVM technology to allow AVMs to be used in rural areas to improve appraisal turnaround times; H.R. 1319, the American Rescue Plan Act of 2021; Provide temporary capital flexibility for the National Credit Union Administration (NCUA) and credit unions, such as a reduction in the level at which credit unions are considered well capitalized; Urges Support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; support relief from the member business loan (MBL) cap; requests that the NCUA consolidate its supervisory guidance into fewer letterheads, improve its website to increase usability, and release timely cybersecurity risk alerts; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; support allowing the GSEs to rebuild capital and ensuring the GSEs are in a safe and sound financial condition before exiting conservatorship to guarantee a healthy and sustainable secondary mortgage market; ensure that any incentives for excessive risk-taking are eliminated but the FHFA should be encouraging the GSEs to focus on increasing opportunities for very-low, low-, and moderate income individuals to purchase a home; support Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act (Economic Aid Act) as part of the year-end stimulus package; support expansion for SBA Interim Final Rule that implements a revised PPP loan calculation formula for Schedule C filers; reject and urge against pilot program for USPS postal banking; support American Rescue Plan Act assistance; exclude credit union member business loans made in response to COVID-19 relief from the credit union member business lending (MBL) cap; urge the Bureau to initiate a rulemaking and exercise its supervisory authority over fintech companies that fall within the scope of a larger participant in the consumer financial services market; urge CFPB to coordinate with the FHFA as it examines its authority to regulate and supervise non-bank mortgage companies; Risk-Based Net Worth-COVID-19 Regulatory Relief; reject ICBAs ongoing attacks on the credit unions; support bank-credit union mergers.
Access to Credit for Small Businesses Impacted by the COVID–19 Crisis Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions
Access to Credit for Small Businesses Impacted by the COVID–19 Crisis Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance; H.R. 133, the Consolidated Appropriations Act of 2021; support efforts to correct gaps in BSA/AML regulations and CVC reporting; urges FinCEN to allow for additional time for stakeholder comments and providing a reasonable implementation period for new requirements; support CDCs recommendation that workers in the finance industry be included as essential workers; support dedicated cash window to include all credit unions; support communication on relevant information regarding the First and Second Draw PPP loans; supports HUDs proposal to amend the FHAs regulations to allow borrowers of single-family properties and other insured properties the option to purchase private flood insurance on FHA-insured mortgages for properties located in Special Flood Hazard Areas (SFHAs) to satisfy the mandatory purchase requirements of the Flood Disaster Protection Act of 1973; support additional investment authorities for credit unions to manage this influx of deposits; support access to credit for small businesses impacted by the COVID-19; support loan maturity extension; FCU Act should allow all credit unions to add underserved areas to their fields of membership; support ESIGN Modernization; expand section 4016 of the CARES Act; parity for credit unions for protections under section 4008 of the CARES Act; expand section 4014 of the CARES Act; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; caution you against making major changes to bankruptcy law; NCUA should (1) immediately issue an interim final rule to provide credit unions parity with recent changes made to community bank threshold standards or offer a different evaluation of credit union assets; and (2) coordinate with the CFPB to provide uniformity in the calculation of credit union assets for purposes of the $10 billion threshold; support efforts to provide flexibility for FCUs to operate their mortgage loan businesses and provide FICUs with another avenue to sell their mortgage servicing rights; support proposed rule to remove the prohibition on the capitalization of interest under Appendix B to Part 741; support authorization of a second PPP loan, simplifying loan forgiveness for PPP loans under the $150,000 threshold and repealing the deduction of EIDL advances from the PPP loan forgiveness amount; Consumer Access to Financial Records; RIN: 3170-AA78; avoid implementing section 1033 in a way that impairs a credit unions ability to protect its members data from the risk of theft or abuse; support update to Chartering and Field of Membership and Shared Facility Requirements, support modernization of the Manual by including online and mobile banking platforms in the definition of service facility; Exempt credit unions from the CECL standard; support proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy; urge the SBA to reduce loan forgiveness review times, focus reviews on larger and riskier loans, and provide consistent processing; opposes any premium that is the direct result of excess share growth rather than material weakness in the Share insurance fund because year-end financials of the SIF reflect the overall strength of the fund; support targeted efforts to help small businesses in these trying times, especially minority- and women-owned businesses that have struggled to access funding; support Homeowner Assistance Fund bill; Ensure that there is a liability shield for businesses that follow the law, protect their employees; raise concerns about legislatively mandated blanket loan forbearance; supports the NCUA having express authority to exempt federally-insured credit unions (FICUs) from suspicious activity report (SAR) requirements; support the FHFAs acknowledgement of the need to modernize appraisals by creating a more streamlined and accurate valuation process, requests that the FHFA require consistent practices among individual appraisers; continue to allow Automated Valuation Models (AVMs) and appraisal waivers to be used for all low-risk mortgage loans; and update the AVM technology to allow AVMs to be used in rural areas to improve appraisal turnaround times; H.R. 1319, the American Rescue Plan Act of 2021; Provide temporary capital flexibility for the National Credit Union Administration (NCUA) and credit unions, such as a reduction in the level at which credit unions are considered well capitalized; Urges Support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; support relief from the member business loan (MBL) cap; requests that the NCUA consolidate its supervisory guidance into fewer letterheads, improve its website to increase usability, and release timely cybersecurity risk alerts; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; support allowing the GSEs to rebuild capital and ensuring the GSEs are in a safe and sound financial condition before exiting conservatorship to guarantee a healthy and sustainable secondary mortgage market; ensure that any incentives for excessive risk-taking are eliminated but the FHFA should be encouraging the GSEs to focus on increasing opportunities for very-low, low-, and moderate income individuals to purchase a home; support Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act (Economic Aid Act) as part of the year-end stimulus package; support expansion for SBA Interim Final Rule that implements a revised PPP loan calculation formula for Schedule C filers; reject and urge against pilot program for USPS postal banking; support American Rescue Plan Act assistance; exclude credit union member business loans made in response to COVID-19 relief from the credit union member business lending (MBL) cap; urge the Bureau to initiate a rulemaking and exercise its supervisory authority over fintech companies that fall within the scope of a larger participant in the consumer financial services market; urge CFPB to coordinate with the FHFA as it examines its authority to regulate and supervise non-bank mortgage companies; Risk-Based Net Worth-COVID-19 Regulatory Relief; reject ICBAs ongoing attacks on the credit unions; support bank-credit union mergers.
Access to Credit for Small Businesses Impacted by the COVID–19 Crisis Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance; H.R. 133, the Consolidated Appropriations Act of 2021; support efforts to correct gaps in BSA/AML regulations and CVC reporting; urges FinCEN to allow for additional time for stakeholder comments and providing a reasonable implementation period for new requirements; support CDCs recommendation that workers in the finance industry be included as essential workers; support dedicated cash window to include all credit unions; support communication on relevant information regarding the First and Second Draw PPP loans; supports HUDs proposal to amend the FHAs regulations to allow borrowers of single-family properties and other insured properties the option to purchase private flood insurance on FHA-insured mortgages for properties located in Special Flood Hazard Areas (SFHAs) to satisfy the mandatory purchase requirements of the Flood Disaster Protection Act of 1973; support additional investment authorities for credit unions to manage this influx of deposits; support access to credit for small businesses impacted by the COVID-19; support loan maturity extension; FCU Act should allow all credit unions to add underserved areas to their fields of membership; support ESIGN Modernization; expand section 4016 of the CARES Act; parity for credit unions for protections under section 4008 of the CARES Act; expand section 4014 of the CARES Act; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; caution you against making major changes to bankruptcy law; NCUA should (1) immediately issue an interim final rule to provide credit unions parity with recent changes made to community bank threshold standards or offer a different evaluation of credit union assets; and (2) coordinate with the CFPB to provide uniformity in the calculation of credit union assets for purposes of the $10 billion threshold; support efforts to provide flexibility for FCUs to operate their mortgage loan businesses and provide FICUs with another avenue to sell their mortgage servicing rights; support proposed rule to remove the prohibition on the capitalization of interest under Appendix B to Part 741; support authorization of a second PPP loan, simplifying loan forgiveness for PPP loans under the $150,000 threshold and repealing the deduction of EIDL advances from the PPP loan forgiveness amount; Consumer Access to Financial Records; RIN: 3170-AA78; avoid implementing section 1033 in a way that impairs a credit unions ability to protect its members data from the risk of theft or abuse; support update to Chartering and Field of Membership and Shared Facility Requirements, support modernization of the Manual by including online and mobile banking platforms in the definition of service facility; Exempt credit unions from the CECL standard; support proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy; urge the SBA to reduce loan forgiveness review times, focus reviews on larger and riskier loans, and provide consistent processing; opposes any premium that is the direct result of excess share growth rather than material weakness in the Share insurance fund because year-end financials of the SIF reflect the overall strength of the fund; support targeted efforts to help small businesses in these trying times, especially minority- and women-owned businesses that have struggled to access funding; support Homeowner Assistance Fund bill; Ensure that there is a liability shield for businesses that follow the law, protect their employees; raise concerns about legislatively mandated blanket loan forbearance; supports the NCUA having express authority to exempt federally-insured credit unions (FICUs) from suspicious activity report (SAR) requirements; support the FHFAs acknowledgement of the need to modernize appraisals by creating a more streamlined and accurate valuation process, requests that the FHFA require consistent practices among individual appraisers; continue to allow Automated Valuation Models (AVMs) and appraisal waivers to be used for all low-risk mortgage loans; and update the AVM technology to allow AVMs to be used in rural areas to improve appraisal turnaround times; H.R. 1319, the American Rescue Plan Act of 2021; Provide temporary capital flexibility for the National Credit Union Administration (NCUA) and credit unions, such as a reduction in the level at which credit unions are considered well capitalized; Urges Support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; support relief from the member business loan (MBL) cap; requests that the NCUA consolidate its supervisory guidance into fewer letterheads, improve its website to increase usability, and release timely cybersecurity risk alerts; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; support allowing the GSEs to rebuild capital and ensuring the GSEs are in a safe and sound financial condition before exiting conservatorship to guarantee a healthy and sustainable secondary mortgage market; ensure that any incentives for excessive risk-taking are eliminated but the FHFA should be encouraging the GSEs to focus on increasing opportunities for very-low, low-, and moderate income individuals to purchase a home; support Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act (Economic Aid Act) as part of the year-end stimulus package; support expansion for SBA Interim Final Rule that implements a revised PPP loan calculation formula for Schedule C filers; reject and urge against pilot program for USPS postal banking; support American Rescue Plan Act assistance; exclude credit union member business loans made in response to COVID-19 relief from the credit union member business lending (MBL) cap; urge the Bureau to initiate a rulemaking and exercise its supervisory authority over fintech companies that fall within the scope of a larger participant in the consumer financial services market; urge CFPB to coordinate with the FHFA as it examines its authority to regulate and supervise non-bank mortgage companies; Risk-Based Net Worth-COVID-19 Regulatory Relief; reject ICBAs ongoing attacks on the credit unions; support bank-credit union mergers.
Access to Credit for Small Businesses Impacted by the COVID–19 Crisis Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions
SAFE Banking Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions
SAFE Banking Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions
Diversity and Inclusion Data Accountability and Transparency Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions
Diversity and Inclusion Data Accountability and Transparency Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions
Credit Union Governance Modernization Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.
Credit Union Governance Modernization Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.
Promoting Diversity and Inclusion in Banking Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions
Promoting Diversity and Inclusion in Banking Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions
Federal Reserve Racial and Economic Equity Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions
Federal Reserve Racial and Economic Equity Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions
Comprehensive Debt Collection Improvement Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions
Comprehensive Debt Collection Improvement Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions
Real Estate Valuation Fairness and Improvement Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions
Real Estate Valuation Fairness and Improvement Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions
Central Liquidity Facility Enhancement Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.
Central Liquidity Facility Enhancement Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.
Central Liquidity Facility Enhancement Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions
Central Liquidity Facility Enhancement Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions
Central Liquidity Facility Enhancement Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.
Central Liquidity Facility Enhancement Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.
Overdraft Protection Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.
Overdraft Protection Act of 2021
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.
Labor, Health and Human Services, Education, Agriculture, Rural Development, Energy and Water Development, Financial Services and General Government, Interior, Environment, Military Construction, Veterans Affairs, Transportation, and Housing and Urban Development Appropriations Act, 2022
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.
Labor, Health and Human Services, Education, Agriculture, Rural Development, Energy and Water Development, Financial Services and General Government, Interior, Environment, Military Construction, Veterans Affairs, Transportation, and Housing and Urban Development Appropriations Act, 2022
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.
Labor, Health and Human Services, Education, Agriculture, Rural Development, Energy and Water Development, Financial Services and General Government, Interior, Environment, Military Construction, Veterans Affairs, Transportation, and Housing and Urban Development Appropriations Act, 2022
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.
Labor, Health and Human Services, Education, Agriculture, Rural Development, Energy and Water Development, Financial Services and General Government, Interior, Environment, Military Construction, Veterans Affairs, Transportation, and Housing and Urban Development Appropriations Act, 2022
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.
Promoting New and Diverse Depository Institutions Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.
Promoting New and Diverse Depository Institutions Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.
Promoting New and Diverse Depository Institutions Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.
Promoting New and Diverse Depository Institutions Act
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Protect the credit union tax exemption
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office
Protect the credit union tax exemption
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office
Protect the credit union tax exemption
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office
Protect the credit union tax exemption
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.
Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office
Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions
Protect the credit union tax exemption
Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office
Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance; H.R. 133, the Consolidated Appropriations Act of 2021; support efforts to correct gaps in BSA/AML regulations and CVC reporting; urges FinCEN to allow for additional time for stakeholder comments and providing a reasonable implementation period for new requirements; support CDCs recommendation that workers in the finance industry be included as essential workers; support dedicated cash window to include all credit unions; support communication on relevant information regarding the First and Second Draw PPP loans; supports HUDs proposal to amend the FHAs regulations to allow borrowers of single-family properties and other insured properties the option to purchase private flood insurance on FHA-insured mortgages for properties located in Special Flood Hazard Areas (SFHAs) to satisfy the mandatory purchase requirements of the Flood Disaster Protection Act of 1973; support additional investment authorities for credit unions to manage this influx of deposits; support access to credit for small businesses impacted by the COVID-19; support loan maturity extension; FCU Act should allow all credit unions to add underserved areas to their fields of membership; support ESIGN Modernization; expand section 4016 of the CARES Act; parity for credit unions for protections under section 4008 of the CARES Act; expand section 4014 of the CARES Act; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; caution you against making major changes to bankruptcy law; NCUA should (1) immediately issue an interim final rule to provide credit unions parity with recent changes made to community bank threshold standards or offer a different evaluation of credit union assets; and (2) coordinate with the CFPB to provide uniformity in the calculation of credit union assets for purposes of the $10 billion threshold; support efforts to provide flexibility for FCUs to operate their mortgage loan businesses and provide FICUs with another avenue to sell their mortgage servicing rights; support proposed rule to remove the prohibition on the capitalization of interest under Appendix B to Part 741; support authorization of a second PPP loan, simplifying loan forgiveness for PPP loans under the $150,000 threshold and repealing the deduction of EIDL advances from the PPP loan forgiveness amount; Consumer Access to Financial Records; RIN: 3170-AA78; avoid implementing section 1033 in a way that impairs a credit unions ability to protect its members data from the risk of theft or abuse; support update to Chartering and Field of Membership and Shared Facility Requirements, support modernization of the Manual by including online and mobile banking platforms in the definition of service facility; Exempt credit unions from the CECL standard; support proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy; urge the SBA to reduce loan forgiveness review times, focus reviews on larger and riskier loans, and provide consistent processing; opposes any premium that is the direct result of excess share growth rather than material weakness in the Share insurance fund because year-end financials of the SIF reflect the overall strength of the fund; support targeted efforts to help small businesses in these trying times, especially minority- and women-owned businesses that have struggled to access funding; support Homeowner Assistance Fund bill; Ensure that there is a liability shield for businesses that follow the law, protect their employees; raise concerns about legislatively mandated blanket loan forbearance; supports the NCUA having express authority to exempt federally-insured credit unions (FICUs) from suspicious activity report (SAR) requirements; support the FHFAs acknowledgement of the need to modernize appraisals by creating a more streamlined and accurate valuation process, requests that the FHFA require consistent practices among individual appraisers; continue to allow Automated Valuation Models (AVMs) and appraisal waivers to be used for all low-risk mortgage loans; and update the AVM technology to allow AVMs to be used in rural areas to improve appraisal turnaround times; H.R. 1319, the American Rescue Plan Act of 2021; Provide temporary capital flexibility for the National Credit Union Administration (NCUA) and credit unions, such as a reduction in the level at which credit unions are considered well capitalized; Urges Support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; support relief from the member business loan (MBL) cap; requests that the NCUA consolidate its supervisory guidance into fewer letterheads, improve its website to increase usability, and release timely cybersecurity risk alerts; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; support allowing the GSEs to rebuild capital and ensuring the GSEs are in a safe and sound financial condition before exiting conservatorship to guarantee a healthy and sustainable secondary mortgage market; ensure that any incentives for excessive risk-taking are eliminated but the FHFA should be encouraging the GSEs to focus on increasing opportunities for very-low, low-, and moderate income individuals to purchase a home; support Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act (Economic Aid Act) as part of the year-end stimulus package; support expansion for SBA Interim Final Rule that implements a revised PPP loan calculation formula for Schedule C filers; reject and urge against pilot program for USPS postal banking; support American Rescue Plan Act assistance; exclude credit union member business loans made in response to COVID-19 relief from the credit union member business lending (MBL) cap; urge the Bureau to initiate a rulemaking and exercise its supervisory authority over fintech companies that fall within the scope of a larger participant in the consumer financial services market; urge CFPB to coordinate with the FHFA as it examines its authority to regulate and supervise non-bank mortgage companies; Risk-Based Net Worth-COVID-19 Regulatory Relief; reject ICBAs ongoing attacks on the credit unions; support bank-credit union mergers.
Protect the credit union tax exemption.
Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; Overhead Transfer Rate (OTR) methodology and operating fee schedule; support of the FCC's efforts to establish and implement exemptions to the TCPAs consent requirement for important information about fraudulent activity, data breaches and available protections, and money transfers; supportive of the FCCs proposal to not limit the number of calls made under the exemption; Comment on Annual Certification and Data Collection Report Form (ACR) and the Certification Transaction Level Report (CTLR), concerned about the reporting burden and cybersecurity risks associated with the proposed ACR and CTRL; support the certainty and regulatory flexibility afforded by many of the new and updated Interagency Questions and Answers regarding flood insurance; express concern the proposed Community Development Financial Institutions Program application creates many such barriers, which ultimately will make it more difficult and unlikely that credit unions will obtain and maintain CDFI-designation; urge the Federal Housing Finance Agency (FHFA) to evaluate top credit union regulatory priorities, Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the National Credit Union Administration (NCUA) to evaluate the priority issues and enact the requested policy modifications re: Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the U.S. Department of the Treasury (Treasury) along with the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) to evaluate the top credit union priorities; express concern with Section 2885 of S.4049, which would expand access to nominal leases on military installations for banks; support for Division F, the Corporate Transparency Act of 2019 and Division G, the COUNTER Act of 2019, of H.R.6395, which would make critical improvements to our Bank Secrecy Act (BSA)/anti-money laundering (AML)/beneficial ownership regime; support of a simplified loan forgiveness process for PPP loans under a $150,000 threshold, such as proposed in H.R.7777/S.4117, the Paycheck Protection Small Business Forgiveness Act; support a second round of PPP loans to the hardest hit small businesses; extend the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) that were enacted in section 4016 of the CARES Act and to extend the provisions from section 4013 of the CARES Act dealing with Troubled Debt Restructuring (TDR); support H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020; support excluding EIDL advances from the PPP forgiveness calculation, as proposed by bipartisan legislation in the House, HR.8361, the EIDL Forgiveness Act; supports legislation, H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020, which would provide temporary relief from the credit union member business lending (MBL) cap; support increase funding for the CDFI and CDRLF programs. Providing $1 billion in emergency funding for the CDFI Fund would allow more credit unions to access monies for specific programs; support the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act); support the inclusion of S.4159, the E-SIGN Modernization Act of 2020, in the relief package; credit unions, as not-for-profit cooperative institutions, should not be subject to the CECL standard; support a reduction in the level at which credit unions are considered well capitalized from a net-worth ratio of seven percent to six percent and adequately capitalized from six percent to five percent during the pandemic; reject any idea, even if well-meaning, that could place new hardships on credit unions; urges the Bureau of Consumer Financial Protection (Bureau or CFPB) to evaluate top credit union priorities, Delay Section 1071 Rulemaking, Electronic Disclosure Relief and Credit Card Accountability Responsibility and Disclosure Act of 2009 Act (CARD Act) Improvements, Temporarily Halt the Qualified Mortgage (QM) Rulemaking, Revise Home Mortgage Disclosure Act (HMDA) Rule and Reporting, Facilitate the London Interbank Offered Rate (LIBOR) Transition, Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Guidance and Rulemaking; urge NCUA provide relief to credit unions as they serve their members during the pandemic: Expanding Virtual Meetings, Managing Unexpected Share Growth, Additional Investment Opportunities, Capitalizing Interest on Loan Modifications, Adopting Broader Capital Reform, Finalizing an Efficient and Measured Budget; supports FinCEN defining an overall effective and reasonably designed AML program, including the explicit requirement for a risk-assessment; support automatic loan forgiveness for PPP loans under $150,000 and support any legislative efforts; support legislative efforts to amend the CARES Act to exclude Economic Injury Disaster Loans (EIDL) advance amounts from the calculation of loan forgiveness under the PPP; support initial 3508EZ form and the newly created 3508S form for loans under $50,000; support H.R. 8361, the EIDL Forgiveness Act; recommend a comment period of 90 days for all novel charter applications including the recent filings by Figure Bank for a national charter and Anchorage for a trust charter; TRACED Act; urged the Commission (FCC) not to impose additional restrictions on the existing exemption for informational calls placed to residential telephone numbers (Informational Calls Exemption); urges FinCEN to retain the current Recordkeeping and Travel Rule thresholds; supports the definition of money as proposed, which will resolve ambiguities surrounding applicability to convertible virtual currencies (CVCs); Thresholds for the Requirement to Collect, Retain, and Transmit Information Under the Recordkeeping and Travel Rules (Docket No.: FINCEN-2020-0002; RIN No.: 1506-AB41); Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support increase in size standards for North American Industry Classification System (NAICS) sectors related to finance and insurance, specifically NAICS code 522130 for credit unions; inclusion of S.4117, the Paycheck Protection Small Business Forgiveness Act; support the extensions of the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) and Troubled Debt Restructuring (TDR) provisions from the CARES Act; support focused clarification of regulatory expectations re: ECOA and Reg B; support HUDs codifying court rulings for disparate impact; support extension of CARES Act provisions: Section 1102: Paycheck Protection Program, Section 4012: Community Bank Leverage Ratio, Section 4014: Current Expected Credit Loss (CECL), Section 4008: Deposit Insurance, Section 4013: Troubled Debt Restructuring (TDR), Section 4016: NCUAs Central Liquidity Facility (CLF), Section 1110: Economic Injury Disaster Loan (EIDL) Program; Conference Report for H.R. 6395, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021; express concern re: The Senates version of the FY 2021 NDAA, S.4049; supports efforts to provide additional emergency funding for CDFIs; outlines several recommendations to improve the efficiency of NCUA budget; bipartisan beneficial ownership and BSA/AML reform legislation - the Corporate Transparency Act and the COUNTER Act; Notice of Ex Parte Presentations, Rules & Regulations Implementing the Tel. Consumer Prot. Act of 1991, CG Docket No. 02-278; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support $25 billion in rental assistance to the Treasury Department to allocate to state and local governments, as well as extends the eviction moratorium; support NCUA modernizing the agencys derivatives rule, changing from a prescriptive approach to a more flexible, principles-based approach; support appreciates the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance ; H.R. 133, the Consolidated Appropriations Act of 2021
Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act
Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.
Protect the credit union tax exemption.
Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements.
Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support legislation such as H.R. 4067, the Financial Inclusion in Banking Act of 2019, which would direct the CFPBs Office of Community Affairs to research how to increase financial inclusion for underserved communities; supports CFPB Director Kathy Kraningers efforts to provide financial institutions with regulatory certainty and targeted relief, while focusing the CFPBs efforts on bad actors; support increased focus on diversity, equity, and inclusion (DEI) within the American economy and the industry; support laws and regulations aimed at detecting and preventing discrimination, as well as the legal mechanisms used to protect fundamental consumer interests; support HUDs objective of updating the Disparate Impact Rule by aligning it more closely with the Supreme Courts decision in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc., (Inclusive Communities); support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support H.R. 2513, the Corporate Transparency Act of 2019 and the COUNTER Act of 2019; support efforts to modernize the Currency Transaction Report (CTR) threshold by indexing it for inflation; support The Business of Insurance Regulatory Reform Act of 2019; support tech sprints; support regulatory efforts to modernize and streamline supervisory processes; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; Support Interbank real-time gross settlement of faster payments docket No. OP-1670; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; advocate against an expanded consumer compliance examination program; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support implementing regulations that clarify that the requirements of the CCPA and its implementing regulations do not apply to organizations that solely collect GLBA-covered information; support a delay in enforcement of the CCPA; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; H.R. 5315, the Expanding Opportunity for MDIs Act, offered by Representative Joyce Beatty (D-OH) and H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019; support keeping legislative reform of the housing finance system as a priority for the Senate Committee on Banking, Housing Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; support S. 2563, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act (ILLICIT CASH Act).
Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.
Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regulations.
Protect the credit union tax exemption.
Protect the credit union tax exemption; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; streamline regulations to allow credit unions to better serve members and cut compliance costs; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time - CRT transactions should be expanded and CSP and single security retained - FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; reforms to the TCPA Act to ensure that credit unions are able to contact their members, S.151; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws(RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; FidelityBonds(RIN3133-AE87) - NCUA should re-evaluate the additional oversight requirements to achieve an operationally efficient and cost-effective solution. NCUA should maintain the current regulation requiring annual review by a federal credit union(FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal.. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; move to confirm NCUA nominees Hood and Harper as soon as possible; move to confirm FHFA Director nominee, Calabria as soon as possible; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; Technical issues with HMDA Platform - CFPB and NCUA should interpret good faith compliance under Regulation C to excuse highly disruptive technical problems that are attributable to the design and programming of the HMDA Platform and clarify how they intend to evaluate errors caused by technical problems on the HMDA Platform that are not the fault of credit unions; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans(RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases.
Protect the credit union tax exemption.
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions; Credit union exemptions from the CFPB; Reforms to the structure of the CFPB and its powers; data and cyber security - creation of a national data security standard; Housing Finance Reform - ensuring that credit unions have unfettered access to the secondary mortgage market based on loan quality rather than quantity; Member Business Lending - raise the arbitrary cap, raise the de minimis exclusion; exempt loans to veterans from the definition of MBL, and exclude non-owner occupied, 1-4-family dwellings from the calculation of the cap on credit union member business loans (H.R. 389/S. 836); Capital Access for Small Businesses and Jobs Act (H.R. 1244); TRID Improvement Act (H.R. 5078/S. 2490); Bank Secrecy Act; FCC Oversight; Patent Reform - provide relief from practices of patent trolls; NFIP - National flood insurance program; The REINS Act (H.R. 26/S. 21); Regulatory Flexibility Act; Improve or require agency regulatory guidance; Financial CHOICE Act (H.R. 10); Community Financial Institution Exemption Act (H.R. 1264); Financial Services for the Underserved Act (H.R. 4665); Senior$afe Act (H.R. 3758/S. 223); Community Mortgage Lender Regulatory Act of 2017 (H.R. 1964); Securing Access to Affordable Mortgage Act of 2017 (H.R. 3221); Greater pre-emption authority for the NCUA; Mortgage Choice Act (H.R. 1153); Preserving Access to Manufactured Housing Act (H.R.1699/S. 1751); Consumer Financial Protection Board Act 2017 (S. 105); Financial Product Safety Commission Act of 2018 (H.R. 5266); TAILOR Act (H.R. 1116/S.366); CFPB Accountability Act of 2017 or the TABS Act of 2017 (H.R. 2553/S.387); Subject CFPB to Congressional appropriations process; Financial Institutions Examination Fairness and Reform Act (H.R. 4545/S. 2237); Expanding SBA business loan programs; Financial Institution Customer Protection Act (H.R. 2706); Financial services and general government appropriations bill; Home Mortgage Disclosure Adjustment Act (H.R. 2954/S. 1310); Home Mortgage Reporting Relief Act of 2017 (H.R. 4648); QM safe harbor for portfolio loans; Portfolio Lending and Mortgage Access Act (H.R. 2226/S. 2013); the Community Lending Enhancement and Regulatory Relief Act (H.R. 2133/S.1002); Common Sense Credit Union Capital Relief Act of 2017 (H.R. 4464); Risk-Based Capital; Common Sense Credit Union Capital Relief Act of 2018 (H.R. 5288/S.3750); Credit Score Competition Act (H.R. 898/S. 1685); Community Institution Mortgage Relief Act of 2017 (H.R. 3971); Small Business 7(a) Lending Oversight Reform Act (H.R. 4743/S.2283); Business of Insurance Regulatory Reform Act of 2017 (H.R. 3746); Subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; Protecting Americans from Credit Entanglements Act (H.R. 1958/S.838); Making Online Banking Initiation Legal and Easy Act of 2017 (H.R. 1457); Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155); Securing Access to Affordable Mortgages Act (H.R. 3221); Protecting Consumers' Access to Credit Act of 2017 (H.R. 3299); H.R. 4296 - related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; the ADA Education and Reform Act of 2017 (H.R. 620); CFPB Examination and Reporting Threshold Act (H.R. 3072). NCUA - Voluntary mergers; reforms to credit union capital requirements; supplemental capital for credit unions; FOM improvements; FCU interest rate cap; asset securitization authority for credit unions; Call report modernization; NCUSIF issues including NOL ratio and equity distribution; short-term small dollar lending; de novo charter process, approvals, and flexibility; consistent examination expectations; Issuance of clear UDAAP expectations; Exam appeals process; Codify IRPS; Bylaws ANPR; Capital Planning and Supervisory Stress Testing; Accuracy of Advertising; support for NCUA Regulatory Reform Agenda; Extend examination cycle for low-risk, well-run credit unions greater than $1 billion in assets; CFPB - Use of Section 1022 exemption authority; rulemakings related to debt collection, overdraft, qualified mortgage, ATR, mortgage servicing, consumer complaint database (and consumer inquiry handling process), Home Mortgage Disclosure Act (HMDA) requirements and reporting thresholds, implementation and examination, prepaid accounts; Section 1071 small business data collection; remittances rule and review; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); free access to credit scores for consumers; Amendments to TILA/RESPA Integrated Disclosure Rule (TRID); Dept. of Treasury - Executive Order implementation, streamlining CDFI certifications, CDFI and CDRLF funding; cybersecurity interagency coordination; Regulation of FinTech companies; Do not subject credit unions to the Community Reinvestment Act (CRA); FCC - TCPA reform and requirements, interpretations, and litigation, fighting robocalls; FHFA - chattel loans/duty to serve; GSEs use of alternative credit scores; Credit Risk Transfer transactions; implementation of the Common Securitization Platform (CSP) and Single Security; FHLB Capital Requirements; FHLB role in mortgage market; SBA - Expanding CU participation in SBA lending; Dept. of Defense - Military Lending Act (MLA) Final Rule changes, guidance and implementation; IRS - guidance related to the tax reform bill, including executive compensation excise tax; Dept. of Labor - Revocation of Fiduciary Duty rule and Overtime rule; Dept. of Justice - ADA standards and guidance related to website accessibility; FTC - frivolous demand letters in violation of the Federal Trade Commission Act; FinCEN - Burden related to Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules, raising the required SAR reporting threshold; combating financial crimes; Federal Reserve - Regulation CC; acceptance of electronically signed loans as pledged collateral; role in payments system; Electronic Signatures; NIST - framework for Improving Critical Infrastructure Cybersecurity; Dept. of VA - Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; FFIEC - evolution of the Cybersecurity Assessment Tool (CAT); FASB - CECL Accounting Standard implementation; Involuntary Liquidation of FCUs and Claims Procedures; Modernizing data collection for supervision of credit unions; FHFA's Affordable Housing Program; IRS oversight of credit unions; FinCEN's Customer Due Diligence Rule; CFPB Civil Investigative Demands and Associated processes; CFPB's Rules of Practice for Adjudication Proceedings; Collection of Checks and other items by Federal Reserve Banks and Funds Transfers Through Fedwire; CFPB's Enforcement Processes; Federal Credit Union Bylaws; CFPB's Supervision Program; Proposed Suspension and Debarment Procedures; FY'19 FSGG Appropriations Bill; CFPB's RFI regarding external engagements; Regulatory Review; CFPB's Rulemaking Processes; the Give Useful Information to Define Effective Compliance Act (H.R. 5534); the Counter Terrorism and Illicit Finance Act (H.R. 6068); Regulatory Changes in Light of S. 2155; CFPB's Adopted Regulations and New Rulemakings Authorities; Volker Rule; Feedback regarding operating vision for the US Faster Payments Council; CFPB's Inherited Regulations and Inherited Rulemaking Authorities; Title VII of H.R. 5841; CFPB financial education programs; financial literacy; Payday Alternative Loans (PALs); privacy risks regarding data sharing and section 1033 of Dodd-Frank; Disparate Impact Standard; Identity Fraud; Variable Interest Rates; Glass-Steagall Act; Credit Bureaus and the Fair Credit Reporting Act; NDAA - bank operations on military bases; USPS banking services; H.R. 5036, the Financial Technology Protection Act; H.R. 6743 - the Consumer Information Notification Requirement Act, NCUAs proposed rulemaking on loans and lines of credit (RIN 3133-AE88); CFPBs proposed policy to Encourage Trial Disclosure Program; NCUA budget; FHFAs Enterprise Capital Requirements (RIN 2590-AA95); FHFAs Uniform Mortgage-Backed Security (RIN 2590-AA94); NCUAs Real Estate Appraisals (3133-AE79); Potential Federal Reserve Actions to Support Interbank Settlement of Faster Payments, RFC (Docket No. OP-1625); SBAs Express Loan Programs; Affiliation Standards (RIN 3245-AG74); CFPB Data Collection and internal data governance policies RFI.
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions; Credit union exemptions from the CFPB; Reforms to the structure of the CFPB and its powers; data and cyber security - creation of a national data security standard; Housing Finance Reform - ensuring that credit unions have unfettered access to the secondary mortgage market based on loan quality rather than quantity; Member Business Lending - raise the arbitrary cap, raise the de minimis exclusion; exempt loans to veterans from the definition of MBL, and exclude non-owner occupied, 1-4-family dwellings from the calculation of the cap on credit union member business loans (H.R. 389/S. 836); Capital Access for Small Businesses and Jobs Act (H.R. 1244); TRID Improvement Act (H.R. 5078/S. 2490); Bank Secrecy Act; FCC Oversight; Patent Reform - provide relief from practices of patent trolls; NFIP - National flood insurance program; The REINS Act (H.R. 26/S. 21); Regulatory Flexibility Act; Improve or require agency regulatory guidance; Financial CHOICE Act (H.R. 10); Community Financial Institution Exemption Act (H.R. 1264); Financial Services for the Underserved Act (H.R. 4665); Senior$afe Act (H.R. 3758/S. 223); Community Mortgage Lender Regulatory Act of 2017 (H.R. 1964); Securing Access to Affordable Mortgage Act of 2017 (H.R. 3221); Greater pre-emption authority for the NCUA; Mortgage Choice Act (H.R. 1153); Preserving Access to Manufactured Housing Act (H.R.1699/S. 1751); Consumer Financial Protection Board Act 2017 (S. 105); Financial Product Safety Commission Act of 2018 (H.R. 5266); TAILOR Act (H.R. 1116/S.366); CFPB Accountability Act of 2017 or the TABS Act of 2017 (H.R. 2553/S.387); Subject CFPB to Congressional appropriations process; Financial Institutions Examination Fairness and Reform Act (H.R. 4545/S. 2237); Expanding SBA business loan programs; Financial Institution Customer Protection Act (H.R. 2706); Financial services and general government appropriations bill; Home Mortgage Disclosure Adjustment Act (H.R. 2954/S. 1310); Home Mortgage Reporting Relief Act of 2017 (H.R. 4648); QM safe harbor for portfolio loans; Portfolio Lending and Mortgage Access Act (H.R. 2226/S. 2013); the Community Lending Enhancement and Regulatory Relief Act (H.R. 2133/S.1002); Common Sense Credit Union Capital Relief Act of 2017 (H.R. 4464); Risk-Based Capital; Common Sense Credit Union Capital Relief Act of 2018 (H.R. 5288); Credit Score Competition Act (H.R. 898/S. 1685); Community Institution Mortgage Relief Act of 2017 (H.R. 3971); Small Business 7(a) Lending Oversight Reform Act (H.R. 4743/S.2283); Business of Insurance Regulatory Reform Act of 2017 (H.R. 3746); Subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; Protecting Americans from Credit Entanglements Act (H.R. 1958/S.838); Making Online Banking Initiation Legal and Easy Act of 2017 (H.R. 1457); Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155); Securing Access to Affordable Mortgages Act (H.R. 3221); Protecting Consumers' Access to Credit Act of 2017 (H.R. 3299); H.R. 4296 - related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; the ADA Education and Reform Act of 2017 (H.R. 620); CFPB Examination and Reporting Threshold Act (H.R. 3072). NCUA - Voluntary mergers; reforms to credit union capital requirements; supplemental capital for credit unions; FOM improvements; FCU interest rate cap; asset securitization authority for credit unions; Call report modernization; NCUSIF issues including NOL ratio and equity distribution; short-term small dollar lending; de novo charter process, approvals, and flexibility; consistent examination expectations; Issuance of clear UDAAP expectations; Exam appeals process; Codify IRPS; Bylaws ANPR; Capital Planning and Supervisory Stress Testing; Accuracy of Advertising; support for NCUA Regulatory Reform Agenda; Extend examination cycle for low-risk, well-run credit unions greater than $1 billion in assets; CFPB - Use of Section 1022 exemption authority; rulemakings related to debt collection, overdraft, qualified mortgage, ATR, mortgage servicing, consumer complaint database (and consumer inquiry handling process), Home Mortgage Disclosure Act (HMDA) requirements and reporting thresholds, implementation and examination, prepaid accounts; Section 1071 small business data collection; remittances rule and review; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); free access to credit scores for consumers; Amendments to TILA/RESPA Integrated Disclosure Rule (TRID); Dept. of Treasury - Executive Order implementation, streamlining CDFI certifications, CDFI and CDRLF funding; cybersecurity interagency coordination; Regulation of FinTech companies; Do not subject credit unions to the Community Reinvestment Act (CRA); FCC - TCPA reform and requirements, interpretations, and litigation, fighting robocalls; FHFA - chattel loans/duty to serve; GSEs use of alternative credit scores; Credit Risk Transfer transactions; implementation of the Common Securitization Platform (CSP) and Single Security; FHLB Capital Requirements; FHLB role in mortgage market; SBA - Expanding CU participation in SBA lending; Dept. of Defense - Military Lending Act (MLA) Final Rule changes, guidance and implementation; IRS - guidance related to the tax reform bill, including executive compensation excise tax; Dept. of Labor - Revocation of Fiduciary Duty rule and Overtime rule; Dept. of Justice - ADA standards and guidance related to website accessibility; FTC - frivolous demand letters in violation of the Federal Trade Commission Act; FinCEN - Burden related to Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules, raising the required SAR reporting threshold; combating financial crimes; Federal Reserve - Regulation CC; acceptance of electronically signed loans as pledged collateral; role in payments system; Electronic Signatures; NIST - framework for Improving Critical Infrastructure Cybersecurity; Dept. of VA - Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; FFIEC - evolution of the Cybersecurity Assessment Tool (CAT); FASB - CECL Accounting Standard implementation; Involuntary Liquidation of FCUs and Claims Procedures; Modernizing data collection for supervision of credit unions; FHFA's Affordable Housing Program; IRS oversight of credit unions; FinCEN's Customer Due Diligence Rule; CFPB Civil Investigative Demands and Associated processes; CFPB's Rules of Practice for Adjudication Proceedings; Collection of Checks and other items by Federal Reserve Banks and Funds Transfers Through Fedwire; CFPB's Enforcement Processes; Federal Credit Union Bylaws; CFPB's Supervision Program; Proposed Suspension and Debarment Procedures; FY'19 FSGG Appropriations Bill; CFPB's RFI regarding external engagements; Regulatory Review; CFPB's Rulemaking Processes; the Give Useful Information to Define Effective Compliance Act (H.R. 5534); the Counter Terrorism and Illicit Finance Act (H.R. 6068); Regulatory Changes in Light of S. 2155; CFPB's Adopted Regulations and New Rulemakings Authorities; Volker Rule; Feedback regarding operating vision for the US Faster Payments Council; CFPB's Inherited Regulations and Inherited Rulemaking Authorities; Title VII of H.R. 5841; CFPB financial education programs; financial literacy; Payday Alternative Loans (PALs); privacy risks regarding data sharing and section 1033 of Dodd-Frank; Disparate Impact Standard; Identity Fraud; Variable Interest Rates; Glass-Steagall Act; Credit Bureaus and the Fair Credit Reporting Act; NDAA - bank operations on military bases; USPS banking services; H.R. 5036, the Financial Technology Protection Act; H.R. 6743 - the Consumer Information Notification Requirement Act.
Protect the credit union tax exemption.
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions; Credit union exemptions from the CFPB; Reforms to the structure of the CFPB and its powers; data and cyber security - creation of a national data security standard; Housing Finance Reform - ensuring that credit unions have unfettered access to the secondary mortgage market based on loan quality rather than quantity; Member Business Lending - raise the arbitrary cap, raise the de minimis exclusion; exempt loans to veterans from the definition of MBL, and exclude non-owner occupied, 1-4-family dwellings from the calculation of the cap on credit union member business loans (H.R. 389/S. 836); Capital Access for Small Businesses and Jobs Act (H.R. 1244); TRID Improvement Act (H.R. 5078/S. 2490); Bank Secrecy Act amendments; FCC Oversight; Patent Reform - provide relief from practices of patent trolls; NFIP - National flood insurance program reauthorization; The REINS Act (H.R. 26/S. 21); Regulatory Flexibility Act; Improve or require agency regulatory guidance; Financial CHOICE Act (H.R. 10); Community Financial Institution Exemption Act (H.R. 1264); Financial Services for the Underserved Act (H.R. 4665); Senior$afe Act (H.R. 3758/S. 223); Community Mortgage Lender Regulatory Act of 2017 (H.R. 1964); Securing Access to Affordable Mortgage Act of 2017 (H.R. 3221); Greater pre-emption authority for the NCUA; Mortgage Choice Act (H.R. 1153); Preserving Access to Manufactured Housing Act (H.R.1699/S. 1751); Consumer Financial Protection Board Act 2017 (S. 105); Financial Product Safety Commission Act of 2018 (H.R. 5266); TAILOR Act (H.R. 1116/S.366); CFPB Accountability Act of 2017 or the TABS Act of 2017 (H.R. 2553/S.387); Subject CFPB to Congressional appropriations process; Financial Institutions Examination Fairness and Reform Act (H.R. 4545/S. 2237); Expanding SBA business loan programs; Financial Institution Customer Protection Act (H.R. 2706); Financial services and general government appropriations bill; Home Mortgage Disclosure Adjustment Act (H.R. 2954/S. 1310); Home Mortgage Reporting Relief Act of 2017 (H.R. 4648); QM safe harbor for portfolio loans; Portfolio Lending and Mortgage Access Act (H.R. 2226/S. 2013); the Community Lending Enhancement and Regulatory Relief Act (H.R. 2133/S.1002); Common Sense Credit Union Capital Relief Act of 2017 (H.R. 4464); Common Sense Credit Union Capital Relief Act of 2018 (H.R. 5288); Credit Score Competition Act (H.R. 898/S. 1685); Community Institution Mortgage Relief Act of 2017 (H.R. 3971); Small Business 7(a) Lending Oversight Reform Act (H.R. 4743/S.2283); Business of Insurance Regulatory Reform Act of 2017 (H.R. 3746); Subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; Protecting Americans from Credit Entanglements Act (H.R. 1958/S.838); Making Online Banking Initiation Legal and Easy Act of 2017 (H.R. 1457); Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155); Securing Access to Affordable Mortgages Act (H.R. 3221); Protecting Consumers' Access to Credit Act of 2017 (H.R. 3299); H.R. 4296 - related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; the ADA Education and Reform Act of 2017 (H.R. 620); CFPB Examination and Reporting Threshold Act (H.R. 3072). NCUA - Voluntary mergers; reforms to credit union capital requirements; supplemental capital for credit unions; FOM improvements; FCU interest rate cap; asset securitization authority for credit unions; Call report modernization; NCUSIF issues including NOL ratio and equity distribution; short-term small dollar lending; de novo charter process, approvals, and flexibility; consistent examination expectations; Issuance of clear UDAAP expectations; Exam appeals process; Codify IRPS; Bylaws ANPR; Capital Planning and Supervisory Stress Testing; Accuracy of Advertising; support for NCUA Regulatory Reform Agenda; Extend examination cycle for low-risk, well-run credit unions greater than $1 billion in assets; CFPB - Use of Section 1022 exemption authority; rulemakings related to debt collection, overdraft, qualified mortgage, ATR, mortgage servicing, consumer complaint database, Home Mortgage Disclosure Act (HMDA) requirements and reporting thresholds, implementation and examination, prepaid accounts; Section 1071 small business data collection; remittances rule and review; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); free access to credit scores for consumers; Amendments to TILA/RESPA Integrated Disclosure Rule (TRID); Dept. of Treasury - Executive Order implementation, streamlining CDFI certifications, CDFI funding; cybersecurity interagency coordination; Regulation of FinTech companies; Do not subject credit unions to the Community Reinvestment Act (CRA); FCC - TCPA reform and requirements, interpretations, and litigation, fighting robocalls; FHFA - chattel loans/duty to serve; GSEs use of alternative credit scores; Credit Risk Transfer transactions; implementation of the Common Securitization Platform (CSP) and Single Security; FHLB Capital Requirements; FHLB role in mortgage market; SBA - Expanding CU participation in SBA lending; Dept. of Defense - Military Lending Act (MLA) Final Rule changes, guidance and implementation; IRS - guidance related to the tax reform bill, including executive compensation excise tax; Dept. of Labor - Revocation of Fiduciary Duty rule and Overtime rule; Dept. of Justice - ADA standards and guidance related to website accessibility; FTC - frivolous demand letters in violation of the Federal Trade Commission Act; FinCEN - Burden related to Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules, raising the required SAR reporting threshold; combating financial crimes; Federal Reserve - Regulation CC; acceptance of electronically signed loans as pledged collateral; role in payments system; NIST - framework for Improving Critical Infrastructure Cybersecurity; Dept. of VA - Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; FFIEC - evolution of the Cybersecurity Assessment Tool (CAT); FASB - CECL Accounting Standard implementation; Involuntary Liquidation of FCUs and Claims Procedures; Modernizing data collection for supervision of credit unions; FHFA's Affordable Housing Program; suggested IRS oversight of credit unions; FinCEN's Customer Due Diligence Rule; CFPB Civil Investigative Demands and Associated processes; CFPB's Rules of Practice for Adjudication Proceedings; Collection of Checks and other items by Federal Reserve Banks and Funds Transfers Through Fedwire; CFPB's Enforcement Processes; Federal Credit Union Bylaws; CFPB's Supervision Program; Proposed Suspension and Debarment Procedures; FY'19 FSGG Appropriations Bill; CFPB's RFI regarding external engagements; Regulatory Review; CFPB's Rulemaking Processes; the Give Useful Information to Define Effective Compliance Act (H.R. 5534); the Counter Terrorism and Illicit Finance Act (H.R. 6068); Regulatory Changes in Light of S. 2155; CFPB's Adopted Regulations and New Rulemakings Authorities; Volker Rule; Feedback regarding operating vision for the US Faster Payments Council; CFPB's Inherited Regulations and Inherited Rulemaking Authorities; Title VII of H.R. 5841.
Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance; H.R. 133, the Consolidated Appropriations Act of 2021; support efforts to correct gaps in BSA/AML regulations and CVC reporting; urges FinCEN to allow for additional time for stakeholder comments and providing a reasonable implementation period for new requirements; support CDCs recommendation that workers in the finance industry be included as essential workers; support dedicated cash window to include all credit unions; support communication on relevant information regarding the First and Second Draw PPP loans; supports HUDs proposal to amend the FHAs regulations to allow borrowers of single-family properties and other insured properties the option to purchase private flood insurance on FHA-insured mortgages for properties located in Special Flood Hazard Areas (SFHAs) to satisfy the mandatory purchase requirements of the Flood Disaster Protection Act of 1973; support additional investment authorities for credit unions to manage this influx of deposits; support access to credit for small businesses impacted by the COVID-19; support loan maturity extension; FCU Act should allow all credit unions to add underserved areas to their fields of membership; support ESIGN Modernization; expand section 4016 of the CARES Act; parity for credit unions for protections under section 4008 of the CARES Act; expand section 4014 of the CARES Act; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; caution you against making major changes to bankruptcy law; NCUA should (1) immediately issue an interim final rule to provide credit unions parity with recent changes made to community bank threshold standards or offer a different evaluation of credit union assets; and (2) coordinate with the CFPB to provide uniformity in the calculation of credit union assets for purposes of the $10 billion threshold; support efforts to provide flexibility for FCUs to operate their mortgage loan businesses and provide FICUs with another avenue to sell their mortgage servicing rights; support proposed rule to remove the prohibition on the capitalization of interest under Appendix B to Part 741; support authorization of a second PPP loan, simplifying loan forgiveness for PPP loans under the $150,000 threshold and repealing the deduction of EIDL advances from the PPP loan forgiveness amount; Consumer Access to Financial Records; RIN: 3170-AA78; avoid implementing section 1033 in a way that impairs a credit unions ability to protect its members data from the risk of theft or abuse; support update to Chartering and Field of Membership and Shared Facility Requirements, support modernization of the Manual by including online and mobile banking platforms in the definition of service facility; Exempt credit unions from the CECL standard; support proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy; urge the SBA to reduce loan forgiveness review times, focus reviews on larger and riskier loans, and provide consistent processing; opposes any premium that is the direct result of excess share growth rather than material weakness in the Share insurance fund because year-end financials of the SIF reflect the overall strength of the fund; support targeted efforts to help small businesses in these trying times, especially minority- and women-owned businesses that have struggled to access funding; support Homeowner Assistance Fund bill; Ensure that there is a liability shield for businesses that follow the law, protect their employees; raise concerns about legislatively mandated blanket loan forbearance; supports the NCUA having express authority to exempt federally-insured credit unions (FICUs) from suspicious activity report (SAR) requirements; support the FHFAs acknowledgement of the need to modernize appraisals by creating a more streamlined and accurate valuation process, requests that the FHFA require consistent practices among individual appraisers; continue to allow Automated Valuation Models (AVMs) and appraisal waivers to be used for all low-risk mortgage loans; and update the AVM technology to allow AVMs to be used in rural areas to improve appraisal turnaround times; H.R. 1319, the American Rescue Plan Act of 2021; Provide temporary capital flexibility for the National Credit Union Administration (NCUA) and credit unions, such as a reduction in the level at which credit unions are considered well capitalized; Urges Support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; support relief from the member business loan (MBL) cap; requests that the NCUA consolidate its supervisory guidance into fewer letterheads, improve its website to increase usability, and release timely cybersecurity risk alerts; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; support allowing the GSEs to rebuild capital and ensuring the GSEs are in a safe and sound financial condition before exiting conservatorship to guarantee a healthy and sustainable secondary mortgage market; ensure that any incentives for excessive risk-taking are eliminated but the FHFA should be encouraging the GSEs to focus on increasing opportunities for very-low, low-, and moderate income individuals to purchase a home; support Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act (Economic Aid Act) as part of the year-end stimulus package; support expansion for SBA Interim Final Rule that implements a revised PPP loan calculation formula for Schedule C filers; reject and urge against pilot program for USPS postal banking; support American Rescue Plan Act assistance; exclude credit union member business loans made in response to COVID-19 relief from the credit union member business lending (MBL) cap; urge the Bureau to initiate a rulemaking and exercise its supervisory authority over fintech companies that fall within the scope of a larger participant in the consumer financial services market; urge CFPB to coordinate with the FHFA as it examines its authority to regulate and supervise non-bank mortgage companies; Risk-Based Net Worth-COVID-19 Regulatory Relief; reject ICBAs ongoing attacks on the credit unions; support bank-credit union mergers.
Protect the credit union tax exemption
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office
Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; Overhead Transfer Rate (OTR) methodology and operating fee schedule; support of the FCC's efforts to establish and implement exemptions to the TCPAs consent requirement for important information about fraudulent activity, data breaches and available protections, and money transfers; supportive of the FCCs proposal to not limit the number of calls made under the exemption; Comment on Annual Certification and Data Collection Report Form (ACR) and the Certification Transaction Level Report (CTLR), concerned about the reporting burden and cybersecurity risks associated with the proposed ACR and CTRL; support the certainty and regulatory flexibility afforded by many of the new and updated Interagency Questions and Answers regarding flood insurance; express concern the proposed Community Development Financial Institutions Program application creates many such barriers, which ultimately will make it more difficult and unlikely that credit unions will obtain and maintain CDFI-designation; urge the Federal Housing Finance Agency (FHFA) to evaluate top credit union regulatory priorities, Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the National Credit Union Administration (NCUA) to evaluate the priority issues and enact the requested policy modifications re: Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the U.S. Department of the Treasury (Treasury) along with the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) to evaluate the top credit union priorities; express concern with Section 2885 of S.4049, which would expand access to nominal leases on military installations for banks; support for Division F, the Corporate Transparency Act of 2019 and Division G, the COUNTER Act of 2019, of H.R.6395, which would make critical improvements to our Bank Secrecy Act (BSA)/anti-money laundering (AML)/beneficial ownership regime; support of a simplified loan forgiveness process for PPP loans under a $150,000 threshold, such as proposed in H.R.7777/S.4117, the Paycheck Protection Small Business Forgiveness Act; support a second round of PPP loans to the hardest hit small businesses; extend the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) that were enacted in section 4016 of the CARES Act and to extend the provisions from section 4013 of the CARES Act dealing with Troubled Debt Restructuring (TDR); support H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020; support excluding EIDL advances from the PPP forgiveness calculation, as proposed by bipartisan legislation in the House, HR.8361, the EIDL Forgiveness Act; supports legislation, H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020, which would provide temporary relief from the credit union member business lending (MBL) cap; support increase funding for the CDFI and CDRLF programs. Providing $1 billion in emergency funding for the CDFI Fund would allow more credit unions to access monies for specific programs; support the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act); support the inclusion of S.4159, the E-SIGN Modernization Act of 2020, in the relief package; credit unions, as not-for-profit cooperative institutions, should not be subject to the CECL standard; support a reduction in the level at which credit unions are considered well capitalized from a net-worth ratio of seven percent to six percent and adequately capitalized from six percent to five percent during the pandemic; reject any idea, even if well-meaning, that could place new hardships on credit unions; urges the Bureau of Consumer Financial Protection (Bureau or CFPB) to evaluate top credit union priorities, Delay Section 1071 Rulemaking, Electronic Disclosure Relief and Credit Card Accountability Responsibility and Disclosure Act of 2009 Act (CARD Act) Improvements, Temporarily Halt the Qualified Mortgage (QM) Rulemaking, Revise Home Mortgage Disclosure Act (HMDA) Rule and Reporting, Facilitate the London Interbank Offered Rate (LIBOR) Transition, Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Guidance and Rulemaking; urge NCUA provide relief to credit unions as they serve their members during the pandemic: Expanding Virtual Meetings, Managing Unexpected Share Growth, Additional Investment Opportunities, Capitalizing Interest on Loan Modifications, Adopting Broader Capital Reform, Finalizing an Efficient and Measured Budget; supports FinCEN defining an overall effective and reasonably designed AML program, including the explicit requirement for a risk-assessment; support automatic loan forgiveness for PPP loans under $150,000 and support any legislative efforts; support legislative efforts to amend the CARES Act to exclude Economic Injury Disaster Loans (EIDL) advance amounts from the calculation of loan forgiveness under the PPP; support initial 3508EZ form and the newly created 3508S form for loans under $50,000; support H.R. 8361, the EIDL Forgiveness Act; recommend a comment period of 90 days for all novel charter applications including the recent filings by Figure Bank for a national charter and Anchorage for a trust charter; TRACED Act; urged the Commission (FCC) not to impose additional restrictions on the existing exemption for informational calls placed to residential telephone numbers (Informational Calls Exemption); urges FinCEN to retain the current Recordkeeping and Travel Rule thresholds; supports the definition of money as proposed, which will resolve ambiguities surrounding applicability to convertible virtual currencies (CVCs); Thresholds for the Requirement to Collect, Retain, and Transmit Information Under the Recordkeeping and Travel Rules (Docket No.: FINCEN-2020-0002; RIN No.: 1506-AB41); Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support increase in size standards for North American Industry Classification System (NAICS) sectors related to finance and insurance, specifically NAICS code 522130 for credit unions; inclusion of S.4117, the Paycheck Protection Small Business Forgiveness Act; support the extensions of the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) and Troubled Debt Restructuring (TDR) provisions from the CARES Act; support focused clarification of regulatory expectations re: ECOA and Reg B; support HUDs codifying court rulings for disparate impact; support extension of CARES Act provisions: Section 1102: Paycheck Protection Program, Section 4012: Community Bank Leverage Ratio, Section 4014: Current Expected Credit Loss (CECL), Section 4008: Deposit Insurance, Section 4013: Troubled Debt Restructuring (TDR), Section 4016: NCUAs Central Liquidity Facility (CLF), Section 1110: Economic Injury Disaster Loan (EIDL) Program; Conference Report for H.R. 6395, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021; express concern re: The Senates version of the FY 2021 NDAA, S.4049; supports efforts to provide additional emergency funding for CDFIs; outlines several recommendations to improve the efficiency of NCUA budget; bipartisan beneficial ownership and BSA/AML reform legislation - the Corporate Transparency Act and the COUNTER Act; Notice of Ex Parte Presentations, Rules & Regulations Implementing the Tel. Consumer Prot. Act of 1991, CG Docket No. 02-278; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support $25 billion in rental assistance to the Treasury Department to allocate to state and local governments, as well as extends the eviction moratorium; support NCUA modernizing the agencys derivatives rule, changing from a prescriptive approach to a more flexible, principles-based approach; support appreciates the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance ; H.R. 133, the Consolidated Appropriations Act of 2021
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office
Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act
Protect the credit union tax exemption.
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office
Protect the credit union tax exemption.
Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office
Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements.
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office
Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support legislation such as H.R. 4067, the Financial Inclusion in Banking Act of 2019, which would direct the CFPBs Office of Community Affairs to research how to increase financial inclusion for underserved communities; supports CFPB Director Kathy Kraningers efforts to provide financial institutions with regulatory certainty and targeted relief, while focusing the CFPBs efforts on bad actors; support increased focus on diversity, equity, and inclusion (DEI) within the American economy and the industry; support laws and regulations aimed at detecting and preventing discrimination, as well as the legal mechanisms used to protect fundamental consumer interests; support HUDs objective of updating the Disparate Impact Rule by aligning it more closely with the Supreme Courts decision in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc., (Inclusive Communities); support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support H.R. 2513, the Corporate Transparency Act of 2019 and the COUNTER Act of 2019; support efforts to modernize the Currency Transaction Report (CTR) threshold by indexing it for inflation; support The Business of Insurance Regulatory Reform Act of 2019; support tech sprints; support regulatory efforts to modernize and streamline supervisory processes; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; Support Interbank real-time gross settlement of faster payments docket No. OP-1670; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; advocate against an expanded consumer compliance examination program; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support implementing regulations that clarify that the requirements of the CCPA and its implementing regulations do not apply to organizations that solely collect GLBA-covered information; support a delay in enforcement of the CCPA; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; H.R. 5315, the Expanding Opportunity for MDIs Act, offered by Representative Joyce Beatty (D-OH) and H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019; support keeping legislative reform of the housing finance system as a priority for the Senate Committee on Banking, Housing Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; support S. 2563, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act (ILLICIT CASH Act).
Protect the credit union tax exemption.
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office
Protect the credit union tax exemption.
Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office
Protect the credit union tax exemption.
Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regualtions;
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office
Protect the credit union tax exemption; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; streamline regulations to allow credit unions to better serve members and cut compliance costs; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time - CRT transactions should be expanded and CSP and single security retained - FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; reforms to the TCPA Act to ensure that credit unions are able to contact their members, S.151; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws(RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; FidelityBonds(RIN3133-AE87) - NCUA should re-evaluate the additional oversight requirements to achieve an operationally efficient and cost-effective solution. NCUA should maintain the current regulation requiring annual review by a federal credit union(FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal.. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; move to confirm NCUA nominees Hood and Harper as soon as possible; move to confirm FHFA Director nominee, Calabria as soon as possible; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; Technical issues with HMDA Platform - CFPB and NCUA should interpret good faith compliance under Regulation C to excuse highly disruptive technical problems that are attributable to the design and programming of the HMDA Platform and clarify how they intend to evaluate errors caused by technical problems on the HMDA Platform that are not the fault of credit unions; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans(RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases.
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions; Credit union exemptions from the CFPB; Reforms to the structure of the CFPB and its powers; data and cyber security - creation of a national data security standard; Housing Finance Reform - ensuring that credit unions have unfettered access to the secondary mortgage market based on loan quality rather than quantity; Member Business Lending - raise the arbitrary cap, raise the de minimis exclusion; exempt loans to veterans from the definition of MBL, and exclude non-owner occupied, 1-4-family dwellings from the calculation of the cap on credit union member business loans (H.R. 389/S. 836); Capital Access for Small Businesses and Jobs Act (H.R. 1244); TRID Improvement Act (H.R. 5078/S. 2490); Bank Secrecy Act; FCC Oversight; Patent Reform - provide relief from practices of patent trolls; NFIP - National flood insurance program; The REINS Act (H.R. 26/S. 21); Regulatory Flexibility Act; Improve or require agency regulatory guidance; Financial CHOICE Act (H.R. 10); Community Financial Institution Exemption Act (H.R. 1264); Financial Services for the Underserved Act (H.R. 4665); Senior$afe Act (H.R. 3758/S. 223); Community Mortgage Lender Regulatory Act of 2017 (H.R. 1964); Securing Access to Affordable Mortgage Act of 2017 (H.R. 3221); Greater pre-emption authority for the NCUA; Mortgage Choice Act (H.R. 1153); Preserving Access to Manufactured Housing Act (H.R.1699/S. 1751); Consumer Financial Protection Board Act 2017 (S. 105); Financial Product Safety Commission Act of 2018 (H.R. 5266); TAILOR Act (H.R. 1116/S.366); CFPB Accountability Act of 2017 or the TABS Act of 2017 (H.R. 2553/S.387); Subject CFPB to Congressional appropriations process; Financial Institutions Examination Fairness and Reform Act (H.R. 4545/S. 2237); Expanding SBA business loan programs; Financial Institution Customer Protection Act (H.R. 2706); Financial services and general government appropriations bill; Home Mortgage Disclosure Adjustment Act (H.R. 2954/S. 1310); Home Mortgage Reporting Relief Act of 2017 (H.R. 4648); QM safe harbor for portfolio loans; Portfolio Lending and Mortgage Access Act (H.R. 2226/S. 2013); the Community Lending Enhancement and Regulatory Relief Act (H.R. 2133/S.1002); Common Sense Credit Union Capital Relief Act of 2017 (H.R. 4464); Risk-Based Capital; Common Sense Credit Union Capital Relief Act of 2018 (H.R. 5288/S.3750); Credit Score Competition Act (H.R. 898/S. 1685); Community Institution Mortgage Relief Act of 2017 (H.R. 3971); Small Business 7(a) Lending Oversight Reform Act (H.R. 4743/S.2283); Business of Insurance Regulatory Reform Act of 2017 (H.R. 3746); Subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; Protecting Americans from Credit Entanglements Act (H.R. 1958/S.838); Making Online Banking Initiation Legal and Easy Act of 2017 (H.R. 1457); Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155); Securing Access to Affordable Mortgages Act (H.R. 3221); Protecting Consumers' Access to Credit Act of 2017 (H.R. 3299); H.R. 4296 - related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; the ADA Education and Reform Act of 2017 (H.R. 620); CFPB Examination and Reporting Threshold Act (H.R. 3072). NCUA - Voluntary mergers; reforms to credit union capital requirements; supplemental capital for credit unions; FOM improvements; FCU interest rate cap; asset securitization authority for credit unions; Call report modernization; NCUSIF issues including NOL ratio and equity distribution; short-term small dollar lending; de novo charter process, approvals, and flexibility; consistent examination expectations; Issuance of clear UDAAP expectations; Exam appeals process; Codify IRPS; Bylaws ANPR; Capital Planning and Supervisory Stress Testing; Accuracy of Advertising; support for NCUA Regulatory Reform Agenda; Extend examination cycle for low-risk, well-run credit unions greater than $1 billion in assets; CFPB - Use of Section 1022 exemption authority; rulemakings related to debt collection, overdraft, qualified mortgage, ATR, mortgage servicing, consumer complaint database (and consumer inquiry handling process), Home Mortgage Disclosure Act (HMDA) requirements and reporting thresholds, implementation and examination, prepaid accounts; Section 1071 small business data collection; remittances rule and review; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); free access to credit scores for consumers; Amendments to TILA/RESPA Integrated Disclosure Rule (TRID); Dept. of Treasury - Executive Order implementation, streamlining CDFI certifications, CDFI and CDRLF funding; cybersecurity interagency coordination; Regulation of FinTech companies; Do not subject credit unions to the Community Reinvestment Act (CRA); FCC - TCPA reform and requirements, interpretations, and litigation, fighting robocalls; FHFA - chattel loans/duty to serve; GSEs use of alternative credit scores; Credit Risk Transfer transactions; implementation of the Common Securitization Platform (CSP) and Single Security; FHLB Capital Requirements; FHLB role in mortgage market; SBA - Expanding CU participation in SBA lending; Dept. of Defense - Military Lending Act (MLA) Final Rule changes, guidance and implementation; IRS - guidance related to the tax reform bill, including executive compensation excise tax; Dept. of Labor - Revocation of Fiduciary Duty rule and Overtime rule; Dept. of Justice - ADA standards and guidance related to website accessibility; FTC - frivolous demand letters in violation of the Federal Trade Commission Act; FinCEN - Burden related to Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules, raising the required SAR reporting threshold; combating financial crimes; Federal Reserve - Regulation CC; acceptance of electronically signed loans as pledged collateral; role in payments system; Electronic Signatures; NIST - framework for Improving Critical Infrastructure Cybersecurity; Dept. of VA - Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; FFIEC - evolution of the Cybersecurity Assessment Tool (CAT); FASB - CECL Accounting Standard implementation; Involuntary Liquidation of FCUs and Claims Procedures; Modernizing data collection for supervision of credit unions; FHFA's Affordable Housing Program; IRS oversight of credit unions; FinCEN's Customer Due Diligence Rule; CFPB Civil Investigative Demands and Associated processes; CFPB's Rules of Practice for Adjudication Proceedings; Collection of Checks and other items by Federal Reserve Banks and Funds Transfers Through Fedwire; CFPB's Enforcement Processes; Federal Credit Union Bylaws; CFPB's Supervision Program; Proposed Suspension and Debarment Procedures; FY'19 FSGG Appropriations Bill; CFPB's RFI regarding external engagements; Regulatory Review; CFPB's Rulemaking Processes; the Give Useful Information to Define Effective Compliance Act (H.R. 5534); the Counter Terrorism and Illicit Finance Act (H.R. 6068); Regulatory Changes in Light of S. 2155; CFPB's Adopted Regulations and New Rulemakings Authorities; Volker Rule; Feedback regarding operating vision for the US Faster Payments Council; CFPB's Inherited Regulations and Inherited Rulemaking Authorities; Title VII of H.R. 5841; CFPB financial education programs; financial literacy; Payday Alternative Loans (PALs); privacy risks regarding data sharing and section 1033 of Dodd-Frank; Disparate Impact Standard; Identity Fraud; Variable Interest Rates; Glass-Steagall Act; Credit Bureaus and the Fair Credit Reporting Act; NDAA - bank operations on military bases; USPS banking services; H.R. 5036, the Financial Technology Protection Act; H.R. 6743 - the Consumer Information Notification Requirement Act, NCUAs proposed rulemaking on loans and lines of credit (RIN 3133-AE88); CFPBs proposed policy to Encourage Trial Disclosure Program; NCUA budget; FHFAs Enterprise Capital Requirements (RIN 2590-AA95); FHFAs Uniform Mortgage-Backed Security (RIN 2590-AA94); NCUAs Real Estate Appraisals (3133-AE79); Potential Federal Reserve Actions to Support Interbank Settlement of Faster Payments, RFC (Docket No. OP-1625); SBAs Express Loan Programs; Affiliation Standards (RIN 3245-AG74); CFPB Data Collection and internal data governance policies RFI.
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Protect the credit union tax exemption.
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions; Credit union exemptions from the CFPB; Reforms to the structure of the CFPB and its powers; data and cyber security - creation of a national data security standard; Housing Finance Reform - ensuring that credit unions have unfettered access to the secondary mortgage market based on loan quality rather than quantity; Member Business Lending - raise the arbitrary cap, raise the de minimis exclusion; exempt loans to veterans from the definition of MBL, and exclude non-owner occupied, 1-4-family dwellings from the calculation of the cap on credit union member business loans (H.R. 389/S. 836); Capital Access for Small Businesses and Jobs Act (H.R. 1244); TRID Improvement Act (H.R. 5078/S. 2490); Bank Secrecy Act; FCC Oversight; Patent Reform - provide relief from practices of patent trolls; NFIP - National flood insurance program; The REINS Act (H.R. 26/S. 21); Regulatory Flexibility Act; Improve or require agency regulatory guidance; Financial CHOICE Act (H.R. 10); Community Financial Institution Exemption Act (H.R. 1264); Financial Services for the Underserved Act (H.R. 4665); Senior$afe Act (H.R. 3758/S. 223); Community Mortgage Lender Regulatory Act of 2017 (H.R. 1964); Securing Access to Affordable Mortgage Act of 2017 (H.R. 3221); Greater pre-emption authority for the NCUA; Mortgage Choice Act (H.R. 1153); Preserving Access to Manufactured Housing Act (H.R.1699/S. 1751); Consumer Financial Protection Board Act 2017 (S. 105); Financial Product Safety Commission Act of 2018 (H.R. 5266); TAILOR Act (H.R. 1116/S.366); CFPB Accountability Act of 2017 or the TABS Act of 2017 (H.R. 2553/S.387); Subject CFPB to Congressional appropriations process; Financial Institutions Examination Fairness and Reform Act (H.R. 4545/S. 2237); Expanding SBA business loan programs; Financial Institution Customer Protection Act (H.R. 2706); Financial services and general government appropriations bill; Home Mortgage Disclosure Adjustment Act (H.R. 2954/S. 1310); Home Mortgage Reporting Relief Act of 2017 (H.R. 4648); QM safe harbor for portfolio loans; Portfolio Lending and Mortgage Access Act (H.R. 2226/S. 2013); the Community Lending Enhancement and Regulatory Relief Act (H.R. 2133/S.1002); Common Sense Credit Union Capital Relief Act of 2017 (H.R. 4464); Risk-Based Capital; Common Sense Credit Union Capital Relief Act of 2018 (H.R. 5288); Credit Score Competition Act (H.R. 898/S. 1685); Community Institution Mortgage Relief Act of 2017 (H.R. 3971); Small Business 7(a) Lending Oversight Reform Act (H.R. 4743/S.2283); Business of Insurance Regulatory Reform Act of 2017 (H.R. 3746); Subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; Protecting Americans from Credit Entanglements Act (H.R. 1958/S.838); Making Online Banking Initiation Legal and Easy Act of 2017 (H.R. 1457); Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155); Securing Access to Affordable Mortgages Act (H.R. 3221); Protecting Consumers' Access to Credit Act of 2017 (H.R. 3299); H.R. 4296 - related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; the ADA Education and Reform Act of 2017 (H.R. 620); CFPB Examination and Reporting Threshold Act (H.R. 3072). NCUA - Voluntary mergers; reforms to credit union capital requirements; supplemental capital for credit unions; FOM improvements; FCU interest rate cap; asset securitization authority for credit unions; Call report modernization; NCUSIF issues including NOL ratio and equity distribution; short-term small dollar lending; de novo charter process, approvals, and flexibility; consistent examination expectations; Issuance of clear UDAAP expectations; Exam appeals process; Codify IRPS; Bylaws ANPR; Capital Planning and Supervisory Stress Testing; Accuracy of Advertising; support for NCUA Regulatory Reform Agenda; Extend examination cycle for low-risk, well-run credit unions greater than $1 billion in assets; CFPB - Use of Section 1022 exemption authority; rulemakings related to debt collection, overdraft, qualified mortgage, ATR, mortgage servicing, consumer complaint database (and consumer inquiry handling process), Home Mortgage Disclosure Act (HMDA) requirements and reporting thresholds, implementation and examination, prepaid accounts; Section 1071 small business data collection; remittances rule and review; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); free access to credit scores for consumers; Amendments to TILA/RESPA Integrated Disclosure Rule (TRID); Dept. of Treasury - Executive Order implementation, streamlining CDFI certifications, CDFI and CDRLF funding; cybersecurity interagency coordination; Regulation of FinTech companies; Do not subject credit unions to the Community Reinvestment Act (CRA); FCC - TCPA reform and requirements, interpretations, and litigation, fighting robocalls; FHFA - chattel loans/duty to serve; GSEs use of alternative credit scores; Credit Risk Transfer transactions; implementation of the Common Securitization Platform (CSP) and Single Security; FHLB Capital Requirements; FHLB role in mortgage market; SBA - Expanding CU participation in SBA lending; Dept. of Defense - Military Lending Act (MLA) Final Rule changes, guidance and implementation; IRS - guidance related to the tax reform bill, including executive compensation excise tax; Dept. of Labor - Revocation of Fiduciary Duty rule and Overtime rule; Dept. of Justice - ADA standards and guidance related to website accessibility; FTC - frivolous demand letters in violation of the Federal Trade Commission Act; FinCEN - Burden related to Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules, raising the required SAR reporting threshold; combating financial crimes; Federal Reserve - Regulation CC; acceptance of electronically signed loans as pledged collateral; role in payments system; Electronic Signatures; NIST - framework for Improving Critical Infrastructure Cybersecurity; Dept. of VA - Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; FFIEC - evolution of the Cybersecurity Assessment Tool (CAT); FASB - CECL Accounting Standard implementation; Involuntary Liquidation of FCUs and Claims Procedures; Modernizing data collection for supervision of credit unions; FHFA's Affordable Housing Program; IRS oversight of credit unions; FinCEN's Customer Due Diligence Rule; CFPB Civil Investigative Demands and Associated processes; CFPB's Rules of Practice for Adjudication Proceedings; Collection of Checks and other items by Federal Reserve Banks and Funds Transfers Through Fedwire; CFPB's Enforcement Processes; Federal Credit Union Bylaws; CFPB's Supervision Program; Proposed Suspension and Debarment Procedures; FY'19 FSGG Appropriations Bill; CFPB's RFI regarding external engagements; Regulatory Review; CFPB's Rulemaking Processes; the Give Useful Information to Define Effective Compliance Act (H.R. 5534); the Counter Terrorism and Illicit Finance Act (H.R. 6068); Regulatory Changes in Light of S. 2155; CFPB's Adopted Regulations and New Rulemakings Authorities; Volker Rule; Feedback regarding operating vision for the US Faster Payments Council; CFPB's Inherited Regulations and Inherited Rulemaking Authorities; Title VII of H.R. 5841; CFPB financial education programs; financial literacy; Payday Alternative Loans (PALs); privacy risks regarding data sharing and section 1033 of Dodd-Frank; Disparate Impact Standard; Identity Fraud; Variable Interest Rates; Glass-Steagall Act; Credit Bureaus and the Fair Credit Reporting Act; NDAA - bank operations on military bases; USPS banking services; H.R. 5036, the Financial Technology Protection Act; H.R. 6743 - the Consumer Information Notification Requirement Act.
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions; Credit union exemptions from the CFPB; Reforms to the structure of the CFPB and its powers; data and cyber security - creation of a national data security standard; Housing Finance Reform - ensuring that credit unions have unfettered access to the secondary mortgage market based on loan quality rather than quantity; Member Business Lending - raise the arbitrary cap, raise the de minimis exclusion; exempt loans to veterans from the definition of MBL, and exclude non-owner occupied, 1-4-family dwellings from the calculation of the cap on credit union member business loans (H.R. 389/S. 836); Capital Access for Small Businesses and Jobs Act (H.R. 1244); TRID Improvement Act (H.R. 5078/S. 2490); Bank Secrecy Act amendments; FCC Oversight; Patent Reform - provide relief from practices of patent trolls; NFIP - National flood insurance program reauthorization; The REINS Act (H.R. 26/S. 21); Regulatory Flexibility Act; Improve or require agency regulatory guidance; Financial CHOICE Act (H.R. 10); Community Financial Institution Exemption Act (H.R. 1264); Financial Services for the Underserved Act (H.R. 4665); Senior$afe Act (H.R. 3758/S. 223); Community Mortgage Lender Regulatory Act of 2017 (H.R. 1964); Securing Access to Affordable Mortgage Act of 2017 (H.R. 3221); Greater pre-emption authority for the NCUA; Mortgage Choice Act (H.R. 1153); Preserving Access to Manufactured Housing Act (H.R.1699/S. 1751); Consumer Financial Protection Board Act 2017 (S. 105); Financial Product Safety Commission Act of 2018 (H.R. 5266); TAILOR Act (H.R. 1116/S.366); CFPB Accountability Act of 2017 or the TABS Act of 2017 (H.R. 2553/S.387); Subject CFPB to Congressional appropriations process; Financial Institutions Examination Fairness and Reform Act (H.R. 4545/S. 2237); Expanding SBA business loan programs; Financial Institution Customer Protection Act (H.R. 2706); Financial services and general government appropriations bill; Home Mortgage Disclosure Adjustment Act (H.R. 2954/S. 1310); Home Mortgage Reporting Relief Act of 2017 (H.R. 4648); QM safe harbor for portfolio loans; Portfolio Lending and Mortgage Access Act (H.R. 2226/S. 2013); the Community Lending Enhancement and Regulatory Relief Act (H.R. 2133/S.1002); Common Sense Credit Union Capital Relief Act of 2017 (H.R. 4464); Common Sense Credit Union Capital Relief Act of 2018 (H.R. 5288); Credit Score Competition Act (H.R. 898/S. 1685); Community Institution Mortgage Relief Act of 2017 (H.R. 3971); Small Business 7(a) Lending Oversight Reform Act (H.R. 4743/S.2283); Business of Insurance Regulatory Reform Act of 2017 (H.R. 3746); Subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; Protecting Americans from Credit Entanglements Act (H.R. 1958/S.838); Making Online Banking Initiation Legal and Easy Act of 2017 (H.R. 1457); Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155); Securing Access to Affordable Mortgages Act (H.R. 3221); Protecting Consumers' Access to Credit Act of 2017 (H.R. 3299); H.R. 4296 - related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; the ADA Education and Reform Act of 2017 (H.R. 620); CFPB Examination and Reporting Threshold Act (H.R. 3072). NCUA - Voluntary mergers; reforms to credit union capital requirements; supplemental capital for credit unions; FOM improvements; FCU interest rate cap; asset securitization authority for credit unions; Call report modernization; NCUSIF issues including NOL ratio and equity distribution; short-term small dollar lending; de novo charter process, approvals, and flexibility; consistent examination expectations; Issuance of clear UDAAP expectations; Exam appeals process; Codify IRPS; Bylaws ANPR; Capital Planning and Supervisory Stress Testing; Accuracy of Advertising; support for NCUA Regulatory Reform Agenda; Extend examination cycle for low-risk, well-run credit unions greater than $1 billion in assets; CFPB - Use of Section 1022 exemption authority; rulemakings related to debt collection, overdraft, qualified mortgage, ATR, mortgage servicing, consumer complaint database, Home Mortgage Disclosure Act (HMDA) requirements and reporting thresholds, implementation and examination, prepaid accounts; Section 1071 small business data collection; remittances rule and review; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); free access to credit scores for consumers; Amendments to TILA/RESPA Integrated Disclosure Rule (TRID); Dept. of Treasury - Executive Order implementation, streamlining CDFI certifications, CDFI funding; cybersecurity interagency coordination; Regulation of FinTech companies; Do not subject credit unions to the Community Reinvestment Act (CRA); FCC - TCPA reform and requirements, interpretations, and litigation, fighting robocalls; FHFA - chattel loans/duty to serve; GSEs use of alternative credit scores; Credit Risk Transfer transactions; implementation of the Common Securitization Platform (CSP) and Single Security; FHLB Capital Requirements; FHLB role in mortgage market; SBA - Expanding CU participation in SBA lending; Dept. of Defense - Military Lending Act (MLA) Final Rule changes, guidance and implementation; IRS - guidance related to the tax reform bill, including executive compensation excise tax; Dept. of Labor - Revocation of Fiduciary Duty rule and Overtime rule; Dept. of Justice - ADA standards and guidance related to website accessibility; FTC - frivolous demand letters in violation of the Federal Trade Commission Act; FinCEN - Burden related to Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules, raising the required SAR reporting threshold; combating financial crimes; Federal Reserve - Regulation CC; acceptance of electronically signed loans as pledged collateral; role in payments system; NIST - framework for Improving Critical Infrastructure Cybersecurity; Dept. of VA - Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; FFIEC - evolution of the Cybersecurity Assessment Tool (CAT); FASB - CECL Accounting Standard implementation; Involuntary Liquidation of FCUs and Claims Procedures; Modernizing data collection for supervision of credit unions; FHFA's Affordable Housing Program; suggested IRS oversight of credit unions; FinCEN's Customer Due Diligence Rule; CFPB Civil Investigative Demands and Associated processes; CFPB's Rules of Practice for Adjudication Proceedings; Collection of Checks and other items by Federal Reserve Banks and Funds Transfers Through Fedwire; CFPB's Enforcement Processes; Federal Credit Union Bylaws; CFPB's Supervision Program; Proposed Suspension and Debarment Procedures; FY'19 FSGG Appropriations Bill; CFPB's RFI regarding external engagements; Regulatory Review; CFPB's Rulemaking Processes; the Give Useful Information to Define Effective Compliance Act (H.R. 5534); the Counter Terrorism and Illicit Finance Act (H.R. 6068); Regulatory Changes in Light of S. 2155; CFPB's Adopted Regulations and New Rulemakings Authorities; Volker Rule; Feedback regarding operating vision for the US Faster Payments Council; CFPB's Inherited Regulations and Inherited Rulemaking Authorities; Title VII of H.R. 5841.
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office