The Bureau of Consumer Financial Protection should conduct an extensive review of the regulations under its jurisdiction, CUNA wrote to the bureau Friday. CUNA sent a copy of its comprehensive white paper to the bureau in response to its request for information (RFI) on inherited regulations and inherited rulemaking authorities.

“This review should streamline requirements, eliminate outdated or superfluous requirements, and provide exemptions for certain industry stakeholders, such as credit unions and CUSOs, where appropriate,” the white paper reads. “It is critical that the Bureau keep in mind that any change in regulation—even a change intended to reduce regulatory burden—comes with a cost.”

CUNA’s recommendations to the bureau include:

• Changes to the Truth in Lending Act-Real Estate Settlement Procedures integrated disclosure (TRID) rule regarding qualified mortgages, waiting periods, cure violations, loan originations and assignee liability clarifications;
• Changes to mortgage servicing regulations involving force-placed hazard insurance notices and expanding small servicer exemptions for Regulation Z and Regulation X;
• Changing its remittances rule to increase the exemption threshold to at least 1,000 and remove consumers’ ability to cancel a transfer for 30 minutes, or longer, following initiation of a transaction;
• Withdrawing debt collection bulletins that attempt to use its Unfair, Deceptive or Abusive Acts or Practices (UDAAP) authority to place new requirements on creditors despite not statutory changes to the Fair Debt Collection Practices Act;
• Modifying its prepaid cards rule so Regulation Z requirements do not apply to the overdraft features of prepaid accounts;
• Issuing an RFI on whether to eliminate or clarify the “abusive” prong of UDAAP and seek feedback on whether any other aspects of its UDAAP authority should be changed.
• Issuing a bulletin clarifying that previous enforcement actions or consent orders that conflict with statutory or judicial precedent create no new compliance expectations; and
• Excluding credit unions from requirements to compile, maintain and submit to the bureau data on certain small business loans.