How to read the money
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.
Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements".
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
Specific issues are shown only where the LDA source assigned them to this lobbyist. Targets apply to the associated filing.
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Source: Senate LDA
Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements".
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements".
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements".
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
Mortgage Choice Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination.
Mortgage Choice Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
Mortgage Choice Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
Mortgage Choice Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination.
Mortgage Choice Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national datasecurity standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA 7(a) business loan program; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL implementation; National Credit Union Share Insurance Fund Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; CFPBs outline on debt collection practices; Qualified Mortgages; Mortgage Servicing and Mortgage Servicing Assets; Consumer Complaint Database; HMDA Requirements; Payday Lending; Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act, CG Docket No. 02-278 and CG Docket No. 05-338; CDFI certification - eliminate redundant required documentation and lesses reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de nov credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws.
Mortgage Choice Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Mortgage Choice Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Mortgage Choice Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national datasecurity standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA 7(a) business loan program; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL implementation; National Credit Union Share Insurance Fund Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; CFPBs outline on debt collection practices; Qualified Mortgages; Mortgage Servicing and Mortgage Servicing Assets; Consumer Complaint Database; HMDA Requirements; Payday Lending; Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act, CG Docket No. 02-278 and CG Docket No. 05-338; CDFI certification - eliminate redundant required documentation and lesses reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de nov credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws.
Capital Access for Small Businesses and Jobs 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Capital Access for Small Businesses and Jobs 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
Capital Access for Small Businesses and Jobs 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national datasecurity standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA 7(a) business loan program; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL implementation; National Credit Union Share Insurance Fund Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; CFPBs outline on debt collection practices; Qualified Mortgages; Mortgage Servicing and Mortgage Servicing Assets; Consumer Complaint Database; HMDA Requirements; Payday Lending; Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act, CG Docket No. 02-278 and CG Docket No. 05-338; CDFI certification - eliminate redundant required documentation and lesses reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de nov credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws.
Capital Access for Small Businesses and Jobs 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
Capital Access for Small Businesses and Jobs 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Capital Access for Small Businesses and Jobs 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination.
Capital Access for Small Businesses and Jobs 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national datasecurity standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA 7(a) business loan program; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL implementation; National Credit Union Share Insurance Fund Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; CFPBs outline on debt collection practices; Qualified Mortgages; Mortgage Servicing and Mortgage Servicing Assets; Consumer Complaint Database; HMDA Requirements; Payday Lending; Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act, CG Docket No. 02-278 and CG Docket No. 05-338; CDFI certification - eliminate redundant required documentation and lesses reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de nov credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws.
Capital Access for Small Businesses and Jobs 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination.
MOBILE Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
MOBILE Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
PACE Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
PACE Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
PACE Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination.
PACE Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
PACE Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
PACE Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination.
CLEARR Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination.
CLEARR Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
CLEARR Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
CLEARR Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination.
CLEARR Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
CLEARR Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
FCRA Liability Harmonization 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
FCRA Liability Harmonization 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
FCRA Liability Harmonization 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
FCRA Liability Harmonization 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
Privacy Notification Technical Clarification 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Privacy Notification Technical Clarification 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Regulations from the Executive in Need of Scrutiny Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Regulations from the Executive in Need of Scrutiny Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Regulations from the Executive in Need of Scrutiny Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national datasecurity standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA 7(a) business loan program; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL implementation; National Credit Union Share Insurance Fund Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; CFPBs outline on debt collection practices; Qualified Mortgages; Mortgage Servicing and Mortgage Servicing Assets; Consumer Complaint Database; HMDA Requirements; Payday Lending; Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act, CG Docket No. 02-278 and CG Docket No. 05-338; CDFI certification - eliminate redundant required documentation and lesses reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de nov credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws.
Regulations from the Executive in Need of Scrutiny Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
Regulations from the Executive in Need of Scrutiny Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination.
Regulations from the Executive in Need of Scrutiny Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
Regulations from the Executive in Need of Scrutiny Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national datasecurity standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA 7(a) business loan program; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL implementation; National Credit Union Share Insurance Fund Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; CFPBs outline on debt collection practices; Qualified Mortgages; Mortgage Servicing and Mortgage Servicing Assets; Consumer Complaint Database; HMDA Requirements; Payday Lending; Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act, CG Docket No. 02-278 and CG Docket No. 05-338; CDFI certification - eliminate redundant required documentation and lesses reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de nov credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws.
Regulations from the Executive in Need of Scrutiny Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination.
Home Mortgage Disclosure Adjustment 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Home Mortgage Disclosure Adjustment 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Bureau of Consumer Financial Protection Examination and Reporting Threshold Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Bureau of Consumer Financial Protection Examination and Reporting Threshold Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Securing Access to Affordable Mortgages 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Securing Access to Affordable Mortgages 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Protecting Consumers' Access to Credit Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Protecting Consumers' Access to Credit Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Senior Safe Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Senior Safe Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Disaster Tax Relief and Airport and Airway Extension Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
Disaster Tax Relief and Airport and Airway Extension Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Disaster Tax Relief and Airport and Airway Extension Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Disaster Tax Relief and Airport and Airway Extension Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
Protecting Advice for Small Savers Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Protecting Advice for Small Savers Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Credit Union Residential Loan Parity 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
Credit Union Residential Loan Parity 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Credit Union Residential Loan Parity 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Credit Union Residential Loan Parity 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
Credit Union Residential Loan Parity 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national datasecurity standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA 7(a) business loan program; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL implementation; National Credit Union Share Insurance Fund Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; CFPBs outline on debt collection practices; Qualified Mortgages; Mortgage Servicing and Mortgage Servicing Assets; Consumer Complaint Database; HMDA Requirements; Payday Lending; Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act, CG Docket No. 02-278 and CG Docket No. 05-338; CDFI certification - eliminate redundant required documentation and lesses reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de nov credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws.
Credit Union Residential Loan Parity 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national datasecurity standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA 7(a) business loan program; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL implementation; National Credit Union Share Insurance Fund Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; CFPBs outline on debt collection practices; Qualified Mortgages; Mortgage Servicing and Mortgage Servicing Assets; Consumer Complaint Database; HMDA Requirements; Payday Lending; Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act, CG Docket No. 02-278 and CG Docket No. 05-338; CDFI certification - eliminate redundant required documentation and lesses reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de nov credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws.
Credit Union Residential Loan Parity 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination.
Credit Union Residential Loan Parity 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination.
Community Institution Mortgage Relief Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Community Institution Mortgage Relief Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Community Institution Mortgage Relief Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
Community Institution Mortgage Relief Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
TRID Improvement Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
TRID Improvement Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
TRID Improvement Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
TRID Improvement Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
To place requirements on operational risk capital requirements for banking organizations established by an appropriate Federal banking agency.
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
To place requirements on operational risk capital requirements for banking organizations established by an appropriate Federal banking agency.
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Common Sense Credit Union Capital Relief Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Common Sense Credit Union Capital Relief Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Financial Institutions Examination Fairness and Reform 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Financial Institutions Examination Fairness and Reform 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)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Risk Management and Homeowner Stability Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national datasecurity standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA 7(a) business loan program; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL implementation; National Credit Union Share Insurance Fund Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; CFPBs outline on debt collection practices; Qualified Mortgages; Mortgage Servicing and Mortgage Servicing Assets; Consumer Complaint Database; HMDA Requirements; Payday Lending; Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act, CG Docket No. 02-278 and CG Docket No. 05-338; CDFI certification - eliminate redundant required documentation and lesses reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de nov credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws.
Risk Management and Homeowner Stability Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination.
Risk Management and Homeowner Stability Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
Risk Management and Homeowner Stability Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination.
Risk Management and Homeowner Stability Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Risk Management and Homeowner Stability Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
Risk Management and Homeowner Stability Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
Risk Management and Homeowner Stability Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national datasecurity standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA 7(a) business loan program; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL implementation; National Credit Union Share Insurance Fund Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; CFPBs outline on debt collection practices; Qualified Mortgages; Mortgage Servicing and Mortgage Servicing Assets; Consumer Complaint Database; HMDA Requirements; Payday Lending; Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act, CG Docket No. 02-278 and CG Docket No. 05-338; CDFI certification - eliminate redundant required documentation and lesses reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de nov credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws.
CLEAR Relief Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
CLEAR Relief Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination.
CLEAR Relief Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
CLEAR Relief Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
CLEAR Relief Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
CLEAR Relief Act of 2017
Client: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS · Firm: NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS)
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination.
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.
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, White House Office
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).
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, 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 and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination.
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination.
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 and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national datasecurity standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA 7(a) business loan program; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL implementation; National Credit Union Share Insurance Fund Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; CFPBs outline on debt collection practices; Qualified Mortgages; Mortgage Servicing and Mortgage Servicing Assets; Consumer Complaint Database; HMDA Requirements; Payday Lending; Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act, CG Docket No. 02-278 and CG Docket No. 05-338; CDFI certification - eliminate redundant required documentation and lesses reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de nov credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws.
Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national datasecurity standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA 7(a) business loan program; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL implementation; National Credit Union Share Insurance Fund Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; CFPBs outline on debt collection practices; Qualified Mortgages; Mortgage Servicing and Mortgage Servicing Assets; Consumer Complaint Database; HMDA Requirements; Payday Lending; Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act, CG Docket No. 02-278 and CG Docket No. 05-338; CDFI certification - eliminate redundant required documentation and lesses reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de nov credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws.
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, White House Office
credit union tax exemption; retention of the credit union tax exemption in any reform efforts.
Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Comments responding to request for information on the FHFAs proposed collection of information relating to the NSEMB; Comments on Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis, RIN 1506-AB25; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPB Proposals; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUAs budget; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; Impact of Federal Regulations on Credit Unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act; CFPBs interim final rule amending Regulation Z; H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; Federal Credit Union Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; Dodd-Frank 1022 Authority; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; NCUAs member business lending rule: update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; Accuracy of advertising and notice of insured status; seek improvements to the NCUA Central Liquidity Facility (CLF); CLF information collection; CLF modernization to obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; prevent arbitration restrictions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; Student Loan Borrower Communication ;CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures, consider good faith efforts to comply with TRID; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; NCUAs usury ceiling under the FCU Act; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission regarding clarifications to the interpretations of the Telephone Consumer Protection Act; FCCs Declaratory Ruling and Order on TCPA; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Uniform Residential Loan Application (URLA); Periodic Statements for Borrowers who have filed for bankruptcy; Statement production systems and CFPBs servicing regulations; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Improve agency use of regulatory guidance; Protect responsible overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB and NCUA; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; Ensure an Effective Payments system; Fairness under FCC ruling on autodialing and FCC oversight; Telephone Consumer Protection Act; modernize online lending laws and regulations; give NCUA greater flexibility with credit union lending including the ability to establish longer maturities for certain loans; preventing g-fees charged by Fannie and Freddie from being used as funding offset; NCUA 18-month Exam Cycle; Military Lending Act Database; Credit Losses Accounting Standard; FASB Accounting Standards; CFPBs expansion of data collection under Reg C, Privacy protections for data collected by CFPB; NIST notice and request for information on views on the Framework for Improving Critical Infrastructure Cybersecurity; Comments on Notice of proposed rulemaking regarding field of membership and chartering; CBSA population limit, combined statistical area, well defined local communities, rural population limits, multiple common bond charters, underserved areas, TIP charters; CFPB information collection on compliance costs and other effects of regulation; Duty to serve underserved markets; interchange rates as related to the Durbin Amendment to Dodd-Frank; Repeal Durbin Amendment; H.R. 5465 - to repeal Durbin Amendment; Federal Reserves EGRPRA review process; FHFAs principal reduction consideration; FFIEC Cybersecurity Assessment Tool; FFIEC proposed revision to the Uniform Interagency Consumer Compliance Rating System; Department of Labor Fiduciary Rule, Department of Labor overtime Rule; Administrative Procedures Act; Regulatory Flexibility for credit unions; Promote Consumer Protection and Financial Literacy; Financial Technology (FinTech); FinTech and online marketplace lending; Transparency for NCUAs Overhead Transfer Rate methodology; Transparency for NCUAs Operating Fee methodology; FY 2017 Financial Services and General Government Appropriations Bill; Community Development Financial Institution funding (CDFI); CDFI certification and reporting requirements; Dept. of Treasurys National Strategy for financial literacy and education; NCUAs information collection on investment and deposit activities; allow credit unions to purchase loans from other originators for purposes of issuing securities; mortgage servicing rights; extend exemption for consumer credit cards from MLA Rule requirements; Secondary Capital for low-income designated credit unions(LICU); LICU information collection burdens; Loan Level Price adjustments and Guaranty Fees; HR5541, Financial Services for the Underserved Act of 2016; NCUAs proposed rule regarding FCU occupancy, planning, and disposal of acquired and abandoned premises; HR 1486, Taking Account of Bureaucrats Spending Act (TABS); HR 4773, the Protection Workplace Advancement and Opportunity Act; HR 4538, the Senior$afe Act; NCUAs proposed rule on Incentive-Based Compensation Arrangement; NCUAs Exam Flexibility Initiative; issues related to the National Credit Union Share Insurance Funds Equity Ratio; NCUAs Regulatory Review; seeking guidance from NCUA on interpretation of overall financial performance; NCUAs Revised Examiner Guidance; NCUA to revise CUSO reporting requirements; CUSO accounting standards, Amend NCUA thresholds for supervisory committee audits and verifications; NCUA to address duplicative nature of Fair Credit Reporting regulations; Incidental Powers; requirements for share insurance; Update call reports; DOJs ANPR on accessibility of web information and services of State and Local Government entities; CFPBs amendment to Regulation Ps Annual Privacy Notice Requirement; NCUAs modernization of data collection for regulatory oversight of credit unions; CFPBs proposed rule on arbitration agreements; Property Assessed Clean Energy (PACE) Loans; NCUAs proposed amendments to the Community Development Revolving Loan Fund; modernization of Federal Credit union Bylaws; FHFAs development of a Common Securitization Platform; NIST request for comment on current and future states of cybersecurity in the digital economy; DOD to give better guidance and extend effective date on Military Lending Act Rule; comments on CFPBs Outline of Proposals Under Consideration and Alternatives Considered regarding Third-Party debt collection practices; comments on Consumer Response Company Response Survey; H.R. 5983, the Financial CHOICE Act; H.R. 4038, the Community Financial Institution Exemption Act; H.R. 6094, Regulatory Relief for Small Businesses, Schools, and Non-Profits Act; CFPBs proposed rule related to Payday, Vehicle Title and Certain High-Cost Installment Loans; Single-Family Credit Risk Transfer and proposals to adopt additional front-end credit risk transfer structures; rebates to credit unions related to the Temporary Corporate Credit Union Stabilization Fund; CFPB request for comment on Amendments Relating to Disclosure of Records and Information; NCUAs 2017 and 2018 proposed budgets; NCUAs Equity Fund Ratio and 2017 Projections; Changes to NCUAs Chartering and Field of Membership Manual.
Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Comments responding to request for information on the FHFAs proposed collection of information relating to the NSEMB; Comments on Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis, RIN 1506-AB25; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPB Proposals; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUAs budget; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; Impact of Federal Regulations on Credit Unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act; CFPBs interim final rule amending Regulation Z; H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; Federal Credit Union Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; Dodd-Frank 1022 Authority; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; NCUAs member business lending rule: update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; Accuracy of advertising and notice of insured status; seek improvements to the NCUA Central Liquidity Facility (CLF); CLF information collection; CLF modernization to obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; prevent arbitration restrictions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; Student Loan Borrower Communication ;CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures, consider good faith efforts to comply with TRID; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; NCUAs usury ceiling under the FCU Act; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission regarding clarifications to the interpretations of the Telephone Consumer Protection Act; FCCs Declaratory Ruling and Order on TCPA; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Uniform Residential Loan Application (URLA); Periodic Statements for Borrowers who have filed for bankruptcy; Statement production systems and CFPBs servicing regulations; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Improve agency use of regulatory guidance; Protect responsible overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB and NCUA; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; Ensure an Effective Payments system; Fairness under FCC ruling on autodialing and FCC oversight; Telephone Consumer Protection Act; modernize online lending laws and regulations; give NCUA greater flexibility with credit union lending including the ability to establish longer maturities for certain loans; preventing g-fees charged by Fannie and Freddie from being used as funding offset; NCUA 18-month Exam Cycle; Military Lending Act Database; Credit Losses Accounting Standard; FASB Accounting Standards; CFPBs expansion of data collection under Reg C, Privacy protections for data collected by CFPB; NIST notice and request for information on views on the Framework for Improving Critical Infrastructure Cybersecurity; Comments on Notice of proposed rulemaking regarding field of membership and chartering; CBSA population limit, combined statistical area, well defined local communities, rural population limits, multiple common bond charters, underserved areas, TIP charters; CFPB information collection on compliance costs and other effects of regulation; Duty to serve underserved markets; interchange rates as related to the Durbin Amendment to Dodd-Frank; Repeal Durbin Amendment; H.R. 5465 - to repeal Durbin Amendment; Federal Reserves EGRPRA review process; FHFAs principal reduction consideration; FFIEC Cybersecurity Assessment Tool; FFIEC proposed revision to the Uniform Interagency Consumer Compliance Rating System; Department of Labor Fiduciary Rule, Department of Labor overtime Rule; Administrative Procedures Act; Regulatory Flexibility for credit unions; Promote Consumer Protection and Financial Literacy; Financial Technology (FinTech); FinTech and online marketplace lending; Transparency for NCUAs Overhead Transfer Rate methodology; Transparency for NCUAs Operating Fee methodology; FY 2017 Financial Services and General Government Appropriations Bill; Community Development Financial Institution funding (CDFI); CDFI certification and reporting requirements; Dept. of Treasurys National Strategy for financial literacy and education; NCUAs information collection on investment and deposit activities; allow credit unions to purchase loans from other originators for purposes of issuing securities; mortgage servicing rights; extend exemption for consumer credit cards from MLA Rule requirements; Secondary Capital for low-income designated credit unions(LICU); LICU information collection burdens; Loan Level Price adjustments and Guaranty Fees; HR5541, Financial Services for the Underserved Act of 2016; NCUAs proposed rule regarding FCU occupancy, planning, and disposal of acquired and abandoned premises; HR 1486, Taking Account of Bureaucrats Spending Act (TABS); HR 4773, the Protection Workplace Advancement and Opportunity Act; HR 4538, the Senior$afe Act; NCUAs proposed rule on Incentive-Based Compensation Arrangement; NCUAs Exam Flexibility Initiative; issues related to the National Credit Union Share Insurance Funds Equity Ratio; NCUAs Regulatory Review; seeking guidance from NCUA on interpretation of overall financial performance; NCUAs Revised Examiner Guidance; NCUA to revise CUSO reporting requirements; CUSO accounting standards, Amend NCUA thresholds for supervisory committee audits and verifications; NCUA to address duplicative nature of Fair Credit Reporting regulations; Incidental Powers; requirements for share insurance; Update call reports; DOJs ANPR on accessibility of web information and services of State and Local Government entities; CFPBs amendment to Regulation Ps Annual Privacy Notice Requirement; NCUAs modernization of data collection for regulatory oversight of credit unions; CFPBs proposed rule on arbitration agreements; Property Assessed Clean Energy (PACE) Loans; NCUAs proposed amendments to the Community Development Revolving Loan Fund; modernization of Federal Credit union Bylaws; FHFAs development of a Common Securitization Platform; NIST request for comment on current and future states of cybersecurity in the digital economy; DOD to give better guidance and extend effective date on Military Lending Act Rule; comments on CFPBs Outline of Proposals Under Consideration and Alternatives Considered regarding Third-Party debt collection practices; comments on Consumer Response Company Response Survey; H.R. 5983, the Financial CHOICE Act; H.R. 4038, the Community Financial Institution Exemption Act; H.R. 6094, Regulatory Relief for Small Businesses, Schools, and Non-Profits Act; CFPBs proposed rule related to Payday, Vehicle Title and Certain High-Cost Installment Loans; Single-Family Credit Risk Transfer and proposals to adopt additional front-end credit risk transfer structures; rebates to credit unions related to the Temporary Corporate Credit Union Stabilization Fund; CFPB request for comment on Amendments Relating to Disclosure of Records and Information; NCUAs 2017 and 2018 proposed budgets; NCUAs Equity Fund Ratio and 2017 Projections; Changes to NCUAs Chartering and Field of Membership Manual.
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
Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Comments responding to request for information on the FHFAs proposed collection of information relating to the NSEMB; Comments on Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis, RIN 1506-AB25; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPB Proposals; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUAs budget; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; Impact of Federal Regulations on Credit Unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act; CFPBs inerim final rule amending Regulation Z; H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; Federal Credit Union Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; Dodd-Frank 1022 Authority; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; NCUAs member business lending rule: update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; Accuracy of advertising and notice of insured status; seek improvements to the NCUA Central Liquidity Facility (CLF); CLF information collection; CLF modernization to obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; prevent arbitration restrictions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; Student Loan Borrower Communication ;CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures, consider good faith efforts to comply with TRID; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; FCCs Declaratory Ruling and Order on TCPA; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Uniform Residential Loan Application (URLA); Periodic Statements for Borrowers who have filed for bankruptcy; Statement production systems and CFPBs servicing regulations; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Improve agency use of regulatory guidance; Protect responsible overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB and NCUA; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; Ensure an Effective Payments system; Fairness under FCC ruling on autodialing and FCC oversight; Telephone Consumer Protection Act; modernize online lending laws and regulations; give NCUA greater flexibility with credit union lending including the ability to establish longer maturities for certain loans; preventing g-fees charged by Fannie and Freddie from being used as funding offset; NCUA 18-month Exam Cycle; Military Lending Act Database; Credit Losses Accounting Standard; FASB Accounting Standards; CFPBs expansion of data collection under Reg C, Privacy protections for data collected by CFPB; NIST notice and request for information on views on the Framework for Improving Critical Infrastructure Cybersecurity; Comments on Notice of proposed rulemaking regarding field of membership and chartering; CBSA population limit, combined statistical area, well defined local communities, rural population limits, multiple common bond charters, underserved areas, TIP charters; CFPB information collection on compliance costs and other effects of regulation; Duty to serve underserved markets; interchange rates as related to the Durbin Amendment to Dodd-Frank; Repeal Durbin Amendment; H.R. 5465 - to repeal Durbin Amendment; Federal Reserves EGRPRA review process; FHFAs principal reduction consideration; FFIEC Cybersecurity Assessment Tool; FFIEC proposed revision to the Uniform Interagency Consumer Compliance Rating System; Department of Labor Fiduciary Rule, Department of Labor overtime Rule; Administrative Procedures Act; Regulatory Flexibility for credit unions; Promote Consumer Protection and Financial Literacy; Financial Technology (FinTech); FinTech and online marketplace lending; Transparency for NCUAs Overhead Transfer Rate methodology; Transparency for NCUAs Operating Fee methodology; FY 2017 Financial Services and General Government Appropriations Bill; Community Development Financial Institution funding (CDFI); CDFI certification and reporting requirements; Dept. of Treasurys National Strategy for financial literacy and education; NCUAs information collection on investment and deposit activities; allow credit unions to purchase loans from other originators for purposes of issuing securities; mortgage servicing rights; extend exemption for consumer credit cards from MLA Rule requirements; Secondary Capital for low-income designated credit unions(LICU); LICU information collection burdens; Loan Level Price adjustments and Guaranty Fees; HR5541, Financial Services for the Underserved Act of 2016; NCUAs proposed rule regarding FCU occupancy, planning, and disposal of acquired and abandoned premises; HR 1486, Taking Account of Bureaucrats Spending Act (TABS); HR 4773, the Protection Workplace Advancement and Opportunity Act; HR 4538, the Senior$afe Act; NCUAs proposed rule on Incentive-Based Compensation Arrangement; NCUAs Exam Flexibility Initiative; issues related to the National Credit Union Share Insurance Funds Equity Ratio; NCUAs Regulatory Review; seeking guidance from NCUA on interpretation of overall financial performance; NCUAs Revised Examiner Guidance; NCUA to revise CUSO reporting requirements; CUSO accounting standards, Amend NCUA thresholds for supervisory committee audits and verifications; NCUA to address duplicative nature of Fair Credit Reporting regulations; Incidental Powers; requirements for share insurance; Update call reports; DOJs ANPR on accessibility of web information and services of State and Local Government entities; CFPBs amendment to Regulation Ps Annual Privacy Notice Requirement; NCUAs modernization of data collection for regulatory oversight of credit unions; CFPBs proposed rule on arbitration agreements; Property Assessed Clean Energy (PACE) Loans; NCUAs proposed amendments to the Community Development Revolving Loan Fund; modernization of Federal Credit union Bylaws; FHFAs development of a Common Securitization Platform; NIST request for comment on current and future states of cybersecurity in the digital economy; DOD to give better guidance and extend effective date on Military Lending Act Rule; comments on CFPBs Outline of Proposals Under Consideration and Alternatives Considered regarding Third-Party debt collection practices; comments on Consumer Response Company Response Survey; H.R. 5983, the Financial CHOICE Act; H.R. 4038, the Community Financial Institution Exemption Act; H.R. 6094, Regulatory Relief for Small Businesses, Schools, and Non-Profits Act.
Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Comments responding to request for information on the FHFAs proposed collection of information relating to the NSEMB; Comments on Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis, RIN 1506-AB25; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPB Proposals; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUA budget transparency; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act; CFPBs inerim final rule amending Regulation Z; H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; Federal Credit Union Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; Dodd-Frank 1022 Authority; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; NCUAs member business lending rule: update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; seek improvements to the NCUA Central Liquidity Facility (CLF); CLF information collection; CLF modernizationobtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; prevent arbitration restrictions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; Student Loan Borrower Communication ;CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures, consider good faith efforts to comply with TRID; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Uniform Residential Loan Application (URLA); Periodic Statements for Borrowers who have filed for bankruptcy; Statement production systems and CFPBs servicing regulations; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Improve agency use of regulatory guidance; Protect responsible overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB and NCUA; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; Ensure an Effective Payments system; Fairness under FCC ruling on autodialing and FCC oversight; Telephone Consumer Protection Act; modernize online lending laws and regulations; give NCUA greater flexibility with credit union lending including the ability to establish longer maturities for certain loans; preventing g-fees charged by Fannie and Freddie from being used as funding offset; NCUA 18-month Exam Cycle; Military Lending Act Database; Credit Losses Accounting Standard; FASB Accounting Standards; CFPBs expansion of data collection under Reg C, Privacy protections for data collected by CFPB; NIST notice and request for information on views on the Framework for Improving Critical Infrastructure Cybersecurity; Comments on Notice of proposed rulemaking regarding field of membership and chartering; CBSA population limit, combined statistical area, well defined local communities, rural population limits, multiple common bond charters, underserved areas, TIP charters; CFPB information collection on compliance costs and other effects of regulation; Duty to serve underserved markets; interchange rates as related to the Durbin Amendment to Dodd-Frank; Repeal Durbin Amendment; Federal Reserves EGRPRA review process; FHFAs principal reduction consideration; FFIEC Cybersecurity Assessment Tool; Department of Labor Fiduciary Rule, Department of Labor overtime Rule; Administrative Procedures Act; Regulatory Flexibility for credit unions; Promote Consumer Protection and Financial Literacy; Financial Technology (FinTech); Transparency for NCUAs Overhead Transfer Rate methodology; Transparency for NCUAs Operating Fee methodology; FY 2017 Financial Services and General Government Appropriations Bill; Community Development Financial Institution funding (CDFI); CDFI certification and reporting requirements; Dept. of Treasurys National Strategy for financial literacy and education; NCUAs information collection on investment and deposit activities; allow credit unions to purchase loans from other originators for purposes of issuing securities; mortgage servicing rights; extend exemption for consumer credit cards from MLA Rule requirements; Secondary Capital for low-income designated credit unions(LICU); LICU information collection burdens; Loan Level Price adjustments and Guaranty Fees; HR5541, Financial Services for the Underserved Act of 2016; NCUAs proposed rule regarding FCU occupancy, planning, and disposal of acquired and abandoned premises; HR 1486, Taking Account of Bureaucrats Spending Act (TABS); HR 4773, the Protection Workplace Advancement and Opportunity Act; HR 4538, the Senior$afe Act.
Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Comments responding to request for information on the FHFAs proposed collection of information relating to the NSEMB; Comments on Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis, RIN 1506-AB25; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPBs Outline of Proposals Under Consideration; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUA budget transparency; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act; H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; NCUAs member business lending rule: update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; seek improvements to the NCUA Central Liquidity Facility; obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures, consider good faith efforts to comply with TRID; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Agency use of regulatory guidance; Protect responsible overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; Ensure an Effective Payments system; Fairness under FCC ruling on autodialing and FCC oversight; modernize online lending laws and regulations; give NCUA greater flexibility with credit union lending including the ability to establish longer maturities for certain loans; preventing g-fees charged by Fannie and Freddie from being used as funding offset; NCUA 18-month Exam Cycle; Military Lending Act Database; Credit Losses Accounting Standard; FASB Accounting Standards; CFPBs expansion of data collection under Reg C, Privacy protections for data collected by CFPB; NIST notice and request for information on views on the Framework for Improving Critical Infrastructure Cybersecurity; Comments on Notice of proposed rulemaking regarding field of membership and chartering; CBSA population limit, combined statistical area, well defined local communities, rural population limits, multiple common bond charters, underserved areas, TIP charters; CFPB information collection on compliance costs and other effects of regulation; Duty to serve underserved markets; interchange rates as related to the Durbin Amendment to Dodd-Frank; Federal Reserves EGRPRA review process; FHFAs principal reduction consideration; FFIEC Cybersecurity Assessment Tool; Department of Labor Overtime Rule; Department of Labor Fiduciary Rule.
credit union tax exemption; retention of the credit union tax exemption in any reform efforts
Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPBs Outline of Proposals Under Consideration; H.R. 601: the Eliminate Privacy Notice Confusion Act; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUA budget transparency; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act;H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; seek improvements to the NCUA Central Liquidity Facility; obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Agency use of regulatory guidance; Overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption.
credit union tax exemption; retention of the credit union tax exemption in any reform efforts
Consumer Financial Protection Bureaus (CFPB) request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures; U.S. Department of Education rule making on student accounts in receipt of Title IV Higher Education Act program funds; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; Federal Housing Finance Agencys calculation to the Housing Price Index; Federal Reserve Boards proposed enhancements to the Federal Reserve Banks Automated Cleaning House Service; U.S. Department of Housing and Urban Development on its proposed revisions to the HUD Addendum to Uniform Residential Loan Application; U.S. Department of Housing and Urban Development proposed rule to the Federal Housing Administrations single-family procedures for filing and calculating claims under the insurance program; National Credit Union Administrations (NCUA) request for comment on the review of its regulations pursuant to the Economic Growth and Regulatory Paperwork Reduction Act of 1996; Federal Financial Institutions Examination Council Cybersecurity Assessment Tool; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NCUAs request for comment on the collection of information related to the final interagency policy statement on diversity policies and practices; NCUAs 2015 Regulatory Review; NCUAs mid-year budget review; NCUAs rules and regulations governing share insurance coverage; NCUAs risk-based capital proposal; Retention of the credit union tax exemption; Cyber security; Data security;S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; H.R. 3038: Highway Transportation Funding Act of 2015; Funding for the Highway Transportation Funding Act of 2015; Additional mortgage reporting requirements for lenders to the Internal Revenue Service; NCUA budget transparency; NCUA third party vendor authority; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; seek improvements to the NCUA Central Liquidity Facility; obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S.A. 2607 to Senate cybersecurity legislation that would allow NCUA to regulate and examine service providers to credit unions; Agency use of regulatory guidance; Overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 601: Eliminate Privacy Notice Confusion Act; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees;H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ Lifting MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 1233: CLEARR Act of 2015; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act;H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; H.R. 2213: To provide for a safe harbor from the enforcement of integrated disclosure requirements for TILA/RESPA; H.R. 2287: To require public hearings on NCUAs budget; H.R. 2769: Risk-Based Capital Study Act; H.R. 3048: Community Financial Institution Exemption Act; H.R. 3192: Homebuyers Assistance Act; S. 423: Privacy Notice Modernization Act of 2015; S. 482: Consumer Financial Protection Bureau Examination and Reporting Threshold Act of 2015; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 812: CLEAR Relief Act of 2015; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; S. 1484: Financial Regulatory Improvement Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; S. 1711: to provide a temporary safe harbor from enforcement of integrated disclosure requirements for mortgage loan transactions under TILA-RESPA; FHFA membership access proposal; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896 TAILOR Act of 2015.
credit union tax exemption; retention of the credit union tax exemption in any reform efforts.
Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Comments responding to request for information on the FHFAs proposed collection of information relating to the NSEMB; Comments on Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis, RIN 1506-AB25; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPB Proposals; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUAs budget; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; Impact of Federal Regulations on Credit Unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act; CFPBs inerim final rule amending Regulation Z; H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; Federal Credit Union Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; Dodd-Frank 1022 Authority; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; NCUAs member business lending rule: update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; Accuracy of advertising and notice of insured status; seek improvements to the NCUA Central Liquidity Facility (CLF); CLF information collection; CLF modernization to obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; prevent arbitration restrictions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; Student Loan Borrower Communication ;CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures, consider good faith efforts to comply with TRID; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; FCCs Declaratory Ruling and Order on TCPA; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Uniform Residential Loan Application (URLA); Periodic Statements for Borrowers who have filed for bankruptcy; Statement production systems and CFPBs servicing regulations; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Improve agency use of regulatory guidance; Protect responsible overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB and NCUA; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; Ensure an Effective Payments system; Fairness under FCC ruling on autodialing and FCC oversight; Telephone Consumer Protection Act; modernize online lending laws and regulations; give NCUA greater flexibility with credit union lending including the ability to establish longer maturities for certain loans; preventing g-fees charged by Fannie and Freddie from being used as funding offset; NCUA 18-month Exam Cycle; Military Lending Act Database; Credit Losses Accounting Standard; FASB Accounting Standards; CFPBs expansion of data collection under Reg C, Privacy protections for data collected by CFPB; NIST notice and request for information on views on the Framework for Improving Critical Infrastructure Cybersecurity; Comments on Notice of proposed rulemaking regarding field of membership and chartering; CBSA population limit, combined statistical area, well defined local communities, rural population limits, multiple common bond charters, underserved areas, TIP charters; CFPB information collection on compliance costs and other effects of regulation; Duty to serve underserved markets; interchange rates as related to the Durbin Amendment to Dodd-Frank; Repeal Durbin Amendment; H.R. 5465 - to repeal Durbin Amendment; Federal Reserves EGRPRA review process; FHFAs principal reduction consideration; FFIEC Cybersecurity Assessment Tool; FFIEC proposed revision to the Uniform Interagency Consumer Compliance Rating System; Department of Labor Fiduciary Rule, Department of Labor overtime Rule; Administrative Procedures Act; Regulatory Flexibility for credit unions; Promote Consumer Protection and Financial Literacy; Financial Technology (FinTech); FinTech and online marketplace lending; Transparency for NCUAs Overhead Transfer Rate methodology; Transparency for NCUAs Operating Fee methodology; FY 2017 Financial Services and General Government Appropriations Bill; Community Development Financial Institution funding (CDFI); CDFI certification and reporting requirements; Dept. of Treasurys National Strategy for financial literacy and education; NCUAs information collection on investment and deposit activities; allow credit unions to purchase loans from other originators for purposes of issuing securities; mortgage servicing rights; extend exemption for consumer credit cards from MLA Rule requirements; Secondary Capital for low-income designated credit unions(LICU); LICU information collection burdens; Loan Level Price adjustments and Guaranty Fees; HR5541, Financial Services for the Underserved Act of 2016; NCUAs proposed rule regarding FCU occupancy, planning, and disposal of acquired and abandoned premises; HR 1486, Taking Account of Bureaucrats Spending Act (TABS); HR 4773, the Protection Workplace Advancement and Opportunity Act; HR 4538, the Senior$afe Act; NCUAs proposed rule on Incentive-Based Compensation Arrangement; NCUAs Exam Flexibility Initiative; issues related to the National Credit Union Share Insurance Funds Equity Ratio; NCUAs Regulatory Review; seeking guidance from NCUA on interpretation of overall financial performance; NCUAs Revised Examiner Guidance; NCUA to revise CUSO reporting requirements; CUSO accounting standards, Amend NCUA thresholds for supervisory committee audits and verifications; NCUA to address duplicative nature of Fair Credit Reporting regulations; Incidental Powers; requirements for share insurance; Update call reports; DOJs ANPR on accessibility of web information and services of State and Local Government entities; CFPBs amendment to Regulation Ps Annual Privacy Notice Requirement; NCUAs modernization of data collection for regulatory oversight of credit unions; CFPBs proposed rule on arbitration agreements; Property Assessed Clean Energy (PACE) Loans; NCUAs proposed amendments to the Community Development Revolving Loan Fund; modernization of Federal Credit union Bylaws; FHFAs development of a Common Securitization Platform; NIST request for comment on current and future states of cybersecurity in the digital economy; DOD to give better guidance and extend effective date on Military Lending Act Rule; comments on CFPBs Outline of Proposals Under Consideration and Alternatives Considered regarding Third-Party debt collection practices; comments on Consumer Response Company Response Survey; H.R. 5983, the Financial CHOICE Act; H.R. 4038, the Community Financial Institution Exemption Act; H.R. 6094, Regulatory Relief for Small Businesses, Schools, and Non-Profits 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
Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Comments responding to request for information on the FHFAs proposed collection of information relating to the NSEMB; Comments on Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis, RIN 1506-AB25; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPB Proposals; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUA budget transparency; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act; CFPBs inerim final rule amending Regulation Z; H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; Federal Credit Union Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; Dodd-Frank 1022 Authority; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; NCUAs member business lending rule: update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; seek improvements to the NCUA Central Liquidity Facility (CLF); CLF information collection; CLF modernizationobtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; prevent arbitration restrictions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; Student Loan Borrower Communication ;CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures, consider good faith efforts to comply with TRID; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Uniform Residential Loan Application (URLA); Periodic Statements for Borrowers who have filed for bankruptcy; Statement production systems and CFPBs servicing regulations; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Improve agency use of regulatory guidance; Protect responsible overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB and NCUA; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; Ensure an Effective Payments system; Fairness under FCC ruling on autodialing and FCC oversight; Telephone Consumer Protection Act; modernize online lending laws and regulations; give NCUA greater flexibility with credit union lending including the ability to establish longer maturities for certain loans; preventing g-fees charged by Fannie and Freddie from being used as funding offset; NCUA 18-month Exam Cycle; Military Lending Act Database; Credit Losses Accounting Standard; FASB Accounting Standards; CFPBs expansion of data collection under Reg C, Privacy protections for data collected by CFPB; NIST notice and request for information on views on the Framework for Improving Critical Infrastructure Cybersecurity; Comments on Notice of proposed rulemaking regarding field of membership and chartering; CBSA population limit, combined statistical area, well defined local communities, rural population limits, multiple common bond charters, underserved areas, TIP charters; CFPB information collection on compliance costs and other effects of regulation; Duty to serve underserved markets; interchange rates as related to the Durbin Amendment to Dodd-Frank; Repeal Durbin Amendment; Federal Reserves EGRPRA review process; FHFAs principal reduction consideration; FFIEC Cybersecurity Assessment Tool; Department of Labor Fiduciary Rule, Department of Labor overtime Rule; Administrative Procedures Act; Regulatory Flexibility for credit unions; Promote Consumer Protection and Financial Literacy; Financial Technology (FinTech); Transparency for NCUAs Overhead Transfer Rate methodology; Transparency for NCUAs Operating Fee methodology; FY 2017 Financial Services and General Government Appropriations Bill; Community Development Financial Institution funding (CDFI); CDFI certification and reporting requirements; Dept. of Treasurys National Strategy for financial literacy and education; NCUAs information collection on investment and deposit activities; allow credit unions to purchase loans from other originators for purposes of issuing securities; mortgage servicing rights; extend exemption for consumer credit cards from MLA Rule requirements; Secondary Capital for low-income designated credit unions(LICU); LICU information collection burdens; Loan Level Price adjustments and Guaranty Fees; HR5541, Financial Services for the Underserved Act of 2016; NCUAs proposed rule regarding FCU occupancy, planning, and disposal of acquired and abandoned premises; HR 1486, Taking Account of Bureaucrats Spending Act (TABS); HR 4773, the Protection Workplace Advancement and Opportunity Act; HR 4538, the Senior$afe Act.
credit union tax exemption; retention of the credit union tax exemption in any reform efforts.
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
Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Comments responding to request for information on the FHFAs proposed collection of information relating to the NSEMB; Comments on Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis, RIN 1506-AB25; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPBs Outline of Proposals Under Consideration; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUA budget transparency; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act; H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; NCUAs member business lending rule: update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; seek improvements to the NCUA Central Liquidity Facility; obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures, consider good faith efforts to comply with TRID; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Agency use of regulatory guidance; Protect responsible overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; Ensure an Effective Payments system; Fairness under FCC ruling on autodialing and FCC oversight; modernize online lending laws and regulations; give NCUA greater flexibility with credit union lending including the ability to establish longer maturities for certain loans; preventing g-fees charged by Fannie and Freddie from being used as funding offset; NCUA 18-month Exam Cycle; Military Lending Act Database; Credit Losses Accounting Standard; FASB Accounting Standards; CFPBs expansion of data collection under Reg C, Privacy protections for data collected by CFPB; NIST notice and request for information on views on the Framework for Improving Critical Infrastructure Cybersecurity; Comments on Notice of proposed rulemaking regarding field of membership and chartering; CBSA population limit, combined statistical area, well defined local communities, rural population limits, multiple common bond charters, underserved areas, TIP charters; CFPB information collection on compliance costs and other effects of regulation; Duty to serve underserved markets; interchange rates as related to the Durbin Amendment to Dodd-Frank; Federal Reserves EGRPRA review process; FHFAs principal reduction consideration; FFIEC Cybersecurity Assessment Tool; Department of Labor Overtime Rule; Department of Labor Fiduciary Rule.
credit union tax exemption; retention of the credit union tax exemption in any reform efforts
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
Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPBs Outline of Proposals Under Consideration; H.R. 601: the Eliminate Privacy Notice Confusion Act; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUA budget transparency; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act;H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; seek improvements to the NCUA Central Liquidity Facility; obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Agency use of regulatory guidance; Overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption.
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), 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), Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Consumer Financial Protection Bureaus (CFPB) request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures; U.S. Department of Education rule making on student accounts in receipt of Title IV Higher Education Act program funds; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; Federal Housing Finance Agencys calculation to the Housing Price Index; Federal Reserve Boards proposed enhancements to the Federal Reserve Banks Automated Cleaning House Service; U.S. Department of Housing and Urban Development on its proposed revisions to the HUD Addendum to Uniform Residential Loan Application; U.S. Department of Housing and Urban Development proposed rule to the Federal Housing Administrations single-family procedures for filing and calculating claims under the insurance program; National Credit Union Administrations (NCUA) request for comment on the review of its regulations pursuant to the Economic Growth and Regulatory Paperwork Reduction Act of 1996; Federal Financial Institutions Examination Council Cybersecurity Assessment Tool; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NCUAs request for comment on the collection of information related to the final interagency policy statement on diversity policies and practices; NCUAs 2015 Regulatory Review; NCUAs mid-year budget review; NCUAs rules and regulations governing share insurance coverage; NCUAs risk-based capital proposal; Retention of the credit union tax exemption; Cyber security; Data security;S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; H.R. 3038: Highway Transportation Funding Act of 2015; Funding for the Highway Transportation Funding Act of 2015; Additional mortgage reporting requirements for lenders to the Internal Revenue Service; NCUA budget transparency; NCUA third party vendor authority; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; seek improvements to the NCUA Central Liquidity Facility; obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S.A. 2607 to Senate cybersecurity legislation that would allow NCUA to regulate and examine service providers to credit unions; Agency use of regulatory guidance; Overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 601: Eliminate Privacy Notice Confusion Act; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees;H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ Lifting MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 1233: CLEARR Act of 2015; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act;H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; H.R. 2213: To provide for a safe harbor from the enforcement of integrated disclosure requirements for TILA/RESPA; H.R. 2287: To require public hearings on NCUAs budget; H.R. 2769: Risk-Based Capital Study Act; H.R. 3048: Community Financial Institution Exemption Act; H.R. 3192: Homebuyers Assistance Act; S. 423: Privacy Notice Modernization Act of 2015; S. 482: Consumer Financial Protection Bureau Examination and Reporting Threshold Act of 2015; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 812: CLEAR Relief Act of 2015; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; S. 1484: Financial Regulatory Improvement Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; S. 1711: to provide a temporary safe harbor from enforcement of integrated disclosure requirements for mortgage loan transactions under TILA-RESPA; FHFA membership access proposal; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015;H.R. 2896 TAILOR Act of 2015.
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), 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), Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office