July is comment deadline for ACH, TRID, IOLTA coverage

June 30, 2015

WASHINGTON (6/30/15)--Comments are due on proposals from the National Credit Union Administration, Consumer Financial Protection Bureau (CFPB) and a number of other agencies in July. CUNA will be submitting comments on each proposal, and welcomes input from stakeholders.

CUNA will also be writing to the NCUA this week in regards to the Federal Accounting Standards Board’s (FASB) credit impairment proposal. CUNA has previously written to FASB citing numerous concerns with the proposal.

This week’s letter to the NCUA will ask the NCUA to work to make the proposal more credit union-friendly.

Comments due in July include:

  • July 2: Federal Reserve request for comment regarding enhancements to same day automated clearing house (ACH) services. This proposal incorporates the NACHA- The Electronic Payments Association’s recently adopted same day ACH operating rules;
  • July 2: Department of Education proposal to amend cash management rules for student loans. The proposal includes significant restrictions on financial products used to disburse credit balance funds to students;
  • July 7: CFPB delay of its Truth in Lending Act-Real Estate Settlement Procedures Act integrated disclosures (TRID) rule. The bureau has proposed to delay the implementation to Oct. 1. Comments can be submitted to CUNA by July 5;
  • July 13: NCUA proposal on providing pass-through share insurance for interest on lawyer trust accounts (IOLTAs) and other similar escrow accounts. This follows the enactment of the Credit Union Share Insurance Fund Parity Act, which was signed into law last December. Comments are due to CUNA by July 8;
  • July 13: CFPB request for comment on the student loan servicing market. The bureau is seeking input on potential options to improve borrower service, reduce defaults, develop best practices, assess consumer protections and spur innovation; and
  • July 20 U.S. Department of Labor proposal defining who is a “fiduciary” of an employee benefit plan under the Employee Retirement Income Security Act of 1974 (ERISA). This proposal considerably expands the number of financial professionals that would be considered ERISA fiduciaries providing advice.