CUNA’s continued outreach and engagement with credit unions and other stakeholders resulted in a letter to Consumer Financial Protection Bureau (CFPB) Director Kathy Kraninger Wednesday detailing additional policy recommendations to help credit unions continue to provide high-quality financial services to members affected by the coronavirus disease (COVID-19) crisis.

“While the COVID-19 pandemic has dramatically changed almost every aspect of everyday life, credit unions are standing true to their mission and continuing to assist their members and communities,” the letter reads. “Any regulatory relief the CFPB can provide for credit unions will greatly help in their efforts to serve their consumers.”

Wednesday’s letter follows up two previous letters from CUNA to Kraninger, one requesting remittance flexibility and one with a set of recommendations.

Recommendations include:

Supervision and Enforcement

• The CFPB should continue to suspend routine onsite examinations and reduce the frequency of requests for examination-related information so credit union employees can dedicate their time to focusing on members.
• CUNA also encourages the CFPB to expand the “good faith efforts” policy to additional areas where credit unions are acting swiftly to assist members in need.
• Specifically, CUNA recommends the adoption of a “good faith efforts” policy regarding Regulation B (Equal Credit Opportunity Act) notices for new credit products intended to assist members during the pandemic

Rulemaking

• The CFPB should extend the compliance deadlines for pending regulatory changes in 2020, unless the regulation reduces requirements. For example, CUNA recommends the CFPB and the Federal Reserve Board extend the July 1, 2020, implementation date for the upcoming changes for Regulation CC (Availability of Funds and Collection of Checks);
• CUNA also called on the CFPB to provide clarity to credit unions regarding the “temporary GSE patch,” which is set to expire on January 10, 2021 by either extending the “patch” or modify the underlying “ability-to-repay” and “qualified mortgage” rules by eliminating the 43% debt-to-income (DTI) ratio and Appendix Q requirements from the safe harbor
• CUNA strongly encourages the CFPB to complete its rulemaking on small dollar lending and either exempt credit unions loans completely from the rule’s requirement or rescind the mandatory underwriting provisions in the 2017 final rule.

Guidance

• CUNA encourages the CFPB to continue to coordinate with other federal banking regulators to issue guidance on mortgage servicing during the COVID-19 pandemic, especially regarding compliance with the Real Estate Settlement Procedures Act.

CUNA also thanked the Kraninger for the CFPB’s actions thus far, including policy statements on mortgage servicing, credit reporting, as well as postponing certain data collections, reducing invasiveness of some exams, and granting flexibility regarding reporting obligations.