6. Complaints. The CFPB will operate a toll-free consumer hotline and website for complaints and questions about consumer financial products and services. The bureau will develop procedures with NCUA and other federal agencies on how to handle consumer complaints in a timely manner.
Expect the bureau to give a lot more attention to member complaints. CUNA will follow this process to ensure a few complaints don’t provide anecdotal evidence for revising regulations.
After the Dodd-Frank Act passed, CUNA strenuously objected as the Fed continued to issue proposed, final, and interim final regulations affecting mortgage lending compliance requirements.
CUNA urged Treasury and the Fed to declare a rule-making moratorium so the CFPB can address changes to mortgage lending requirements in a comprehensive manner.
Last month, the Fed announced it would not finalize its 2009 proposed overhaul of Reg Z’s closed-end mortgage and home equity loan rules along with its Sept. 2010 proposals that would change credit life and disability insurance disclosures and right-of-rescission rules, leaving it to the CFPB to decide how to proceed.
8. Consumer lending. Warren has said another high priority of the new bureau must be to look at credit card disclosures. Credit unions and other card issuers had to make notable changes in their credit card programs in the past two years to comply with the Credit Card Accountability, Responsibility, and Disclosure (CARD) Act.
One provision of the CARD Act requires public disclosure on a Fed website of many credit card agreements. Warren argues that consumers don’t understand credit card disclosures, and therefore can’t adequately compare options.
So expect the CFPB to revisit certain open-end Reg Z requirements, even though they’ve already been revised more than once in recent years.
CUNA and other credit union representatives have attended numerous meetings with Warren since mid-2010. She recognizes credit unions’ consumer orientation and significant regulatory burden. She spoke these encouraging words in early 2011: “We need to make compliance easier for lenders, and this is particularly important for credit unions and community banks.”
It remains to be seen whether or not the CFPB will fulfill this objective.
KATHY THOMPSON is CUNA’s senior vice president for compliance and legislative analysis. Address compliance questions to email@example.com.