The Consumer Financial Protection Bureau’s (CFPB) execution of its regulatory agenda should ensure credit unions and other entities are able to provide efficient, safe and affordable products and services, CUNA wrote to the House Financial Services Committee Tuesday. CFPB Director Kathy Kraninger is scheduled to appear before the committee Wednesday.

“The need for consumer protection remains, but rulemakings must be targeted to address the problems in the industry and exclude credit unions from additional requirements when credit unions are not engaged in the problematic activity,” the letter reads. “We look forward to collaborating with the CFPB and Congress to improve upon the past work of the Bureau, while strongly supporting a continued focus on reigning in bad actors in the financial services marketplace.”

CUNA emphasized its support for a bipartisan, multimember commission to lead the CFPB, believing it would offer consistency and transparency to the financial services marketplace. CUNA reiterated this support recently as House Democrats and Kraninger have publicly stated differences in options over the leadership of the CFPB.

CUNA’s letter also recommended the CFPB:

• Closely monitor the impact its rules have had on credit unions and their members, and to appropriately tailor regulations to reduce burden or exempt credit unions entirely;
• Use its statutory authority to grant appropriate exemptions from CFPB regulatory requirements;
• Revise its short-term, small-dollar rule to ensure credit union participation in the market and to focus on abusers of consumers;
• Substantially amend its remittances rule to make it more tailored to allow consumer access to desired products and services;
• Consider additional amendments to Home Mortgage Disclosure Act reporting requirements to provide meaningful exemptions to credit unions;
• Consider potential revisions to the Ability-to-Repay/Qualified Mortgage rule, which would include a “meaningful and prolonged feedback process;”
• Issue a rulemaking that would clarify the CFPB’s Unfair, Deceptive or Abusive Acts or Practices approach, which CUNA believes is currently overly subjective;
• Exempt credit unions from any potential rulemaking to require financial institutions to compile, maintain and submit certain data on small business credit applications.
• Continue its engagement with the credit union industry through the Credit Union Advisory Council, roundtable discussions, webinars and other open communications;
• Base its rulemakings on thorough data and research;
• Provide compliance resources to the financial industry, including frequently asked questions with interpretations, webinars with opportunities for questions, annual outreach to stakeholders, among others. ‘
• Work with CUNA, credit unions and the National Credit Union Foundation in its consumer education efforts, and use those efforts to guide consumer choices and provide a foundation for solid consumer financial health.