The Bureau of Consumer Financial Protection should look closely at its rules and streamline regulations or exempt credit unions entirely, CUNA wrote to the bureau Tuesday. CUNA submitted a copy of its comprehensive white paper to the bureau in response to its request for information on adopted regulations and new rulemaking authority.

“The bureau’s rules should focus on Wall Street banks and the unregulated and under-regulated sectors of the financial services industry. If the Bureau spent less time regulating and supervising credit unions, it could spend more time on the abusers of consumers,"  the white paper reads.

CUNA highlighted the bureau’s payday lending rule as an example of a rulemaking that “would have benefited from more external stakeholder engagement,” before moving forward.

“As the bureau moves forward with new rulemakings, we encourage it to make use of the Advance Notice of Proposed Rulemaking (ANPR) process to solicit additional stakeholder views, and work with the Small Business Administration (SBA) to ensure that the Small Business Regulatory Enforcement Fairness Act (SBREFA) process is efficient and effective,” the paper reads. “Once rules are finalized, the guidance provided by the Bureau must be accurate, easy to understand, and timely; and, enforcement must be fair.”

CUNA also recommended that the bureau:

• Apply a cost/benefit analysis to rules for credit unions;
• Be wholly transparent in its reliance on data, enduring the public has access to the same information, absent confidential and personally identifiable information, it relies on as a foundation of its rulemakings; and
• Engage with NCUA throughout the entire rulemaking process, as NCUA understands the unique structure and business model of credit unions.