CUNA presented the Bureau of Consumer Financial Protection with a comprehensive white paper, “CUNA's Common-Sense Reforms to Bureau of Consumer Financial Protection Rules and Procedures,” Tuesday, as part of CUNA’s continued advocacy efforts in the wake of S. 2155 being signed into law. The white paper provides comments and recommendations to the bureau on its series of requests for information seeking feedback on how it performs its functions.

"As the Bureau has acknowledged, credit unions were not responsible for the 2008 financial crisis, and were instead the trusted institutions that consumers looked to for safe and competitively priced financial products and services," the paper said. "Therefore, CUNA strongly believes the Bureau’s efforts and resources should focus on the problem actors in the industry, not credit unions."

CUNA’s Campaign for Common-Sense Regulation contains several goals for the future of the bureau. Those goals are designed to ensure rules and regulations are tailored and streamlined to focus on problem actors in the financial services industry, not credit unions.

Other recommendations from CUNA’s white paper include:

• The bureau must understand the unique structure and business model of credit unions as member-owned financial services institutions that are inherently consumer friendly;
• Thus, the bureau must focus on the problem actors in the industry, not credit unions. To do so, actions must be taken to provide exemptions for credit unions in current and future regulations;
• The bureau must actively engage with the credit union industry through meetings, roundtable discussions, and the preservation of its Credit Union Advisory Council;
• The bureau must adjust its rulemaking processes so it can effectively receive feedback from the financial services industry; and
• The bureau must work with NCUA regarding any rulemakings or actions involving credit unions.

"CUNA recommendations articulated in this paper are ones the Bureau can and should implement to better focus its time, effort, and resources on the problem actors in the industry, upholding the intent of the Dodd-Frank Act," the paper concluded.