Comments on a proposed delay of the current expected credit loss (CECL) standard and NCUA’s “Second Chance” proposal are among the items with comments due in the September. A complete list of comment deadlines can be found on CUNA’s advocacy actions page.

CECL is a new accounting standard that uses an “expected loss” measurement for the recognition of credit losses. The Financial Accounting Standards Board, who issued CECL, proposed a delay for CECL as it applies to credit unions to January 2023 (past the currently scheduled January 2022).

Specifically, the proposal would create two groups with different implementation dates: Securities and Exchange Commission filers (except for small reporting companies as defined by the SEC) and all others, including credit unions.

Comments are due Sept. 16.

Other comment deadlines this month include:

• Sept. 16: CFPB advance notice of proposed rulemaking on the definition of Qualified Mortgage. The ANPR requests information about possible revisions to Regulation Z’s general definition of Qualified Mortgage in light of the scheduled Jan. 10, 2021 expiration of QMs eligible for purchase or guarantee by either Fannie Mae or Freddie Mac;
• Sept. 18: CFPB proposal to amend part of the regulations implementing the Fair Debt Collection Practices Act to, among other things, address communications in connection with debt collection; interpret and apply prohibitions on harassment or abuse, false or misleading representations, and unfair practices in debt collection; and clarify requirements for certain consumer-facing debt collection disclosures; and
• Sept. 27: NCUA proposal to update and revise its Interpretive Ruling and Policy Statement (IRPS) regarding statutory prohibitions imposed by Section 205(d) of the Federal Credit Union Act to not require n application for insufficient funds checks of aggregate moderate value, small dollar simple theft, false identification, simple drug possession, and isolated minor offenses committed by covered persons as young adults.