The Consumer Financial Protection Bureau (CFPB) has missed many opportunities to leverage credit unions’ mission and history to benefit consumers, CUNA wrote to House Financial Services Committee leadership Wednesday. CFPB Director Rohit Chopra testified before the committee Wednesday, and is scheduled to testify before the Senate Banking, Housing, and Urban Affairs Committee Thursday.

“Consumers lose when one-size-fits-all rules force credit unions to pull back safe and affordable options from the market, pushing consumers into the arms of entities engaged in the very activity the CFPB’s rules were designed to curtail,” the letter reads. “Under Director Rohit Chopra’s leadership, the Bureau has yet again missed numerous opportunities to recalibrate its approach to regulation in a manner that fulfills its consumer protection mission without impeding consumers’ access to credit or safe and affordable financial products and services.”

CUNA highlights the following principles it believes should guide any CFPB action:

• Use the Bureau’s authority in a manner consistent with the original purpose of the CFPB and the spirit of the Dodd-Frank Act.
• Appropriately tailor regulations to reduce disruption for community-based financial institutions.
• Be consistent and transparent during the development and implementation of rulemakings and supervision and enforcement policies.
• Regularly engage stakeholders throughout the policymaking process.
• Consult with NCUA during the policymaking process and avoid implementing duplicative or contradictory policies.
• Provide certainty to regulated entities by adopting clear “rules of the road” and prioritizing internal consistency.
• Conduct thorough research prior to the adoption of a new rule or policy and base policy decisions on relevant data.
• Ensure continued access to credit from reputable providers.
• Encourage and support innovation in the consumer financial services marketplace.

CUNA also noted additional areas of concern for credit unions, including the CFPB’s RFI on fees, small business data collection, regulation of new and emerging service providers, credit reporting, an all-in interest rate cap, and debt collection.