The Consumer Financial Protection Bureau (CFPB) should tailor rules to not be overly burdensome on credit unions, as credit unions are the original consumer financial protectors. CUNA submitted comments to the Senate Banking, Housing, and Urban Affairs Committee Tuesday for CFPB Director Rohit Chopra’s testimony before the committee.

“The CFPB has missed many opportunities to leverage credit unions’ mission and history to the benefit of consumers and finalized regulations that ultimately hampered credit unions and their members,” the letter reads. “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.

“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,” it adds.

CUNA highlighted several principles it believes should guide CFPB actions, including:

• 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.
• 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 raised additional areas of concern with the CFPB, including its broad classification of “junk fees;” increasing financial services engagement with unregulated providers; the importance of an accurate credit reporting system; strong opposition to any proposal with a national “all in” usury cap; and caution regarding any legislation to expand the scope of the Fair Debt Collection Practices Act.

Chopra is scheduled to testify Wednesday before the House Financial Services Committee.