CUNA calls for new CFPB proposal on Regulation CC

September 27, 2017

The Consumer Financial Protection Bureau (CFPB) should re-propose changes to Regulation CC (which governs the Expedited Funds Availability Act) first proposed by the Federal Reserve in 2011. CUNA wrote to the bureau Wednesday highlighting the significant concerns it raised in 2011.

“We have significant concerns that the proposal would substantially increase fraud-related and compliance costs if adopted… Therefore, we urge the bureau to review our comment letter, which includes recommendations to improve the proposed changes,” the letter reads. “The proposed changes were issued by the Fed over 6 years ago. We encourage all agencies to finalize proposals on any topic in a shorter timeframe than 6 years; ideally, within 1 year at most. Matters involving technological issues, such as the proposed changes at issue, necessitate an even shorter timeframe.”

The Fed’s proposal is intended to facilitate the financial services industry’s ongoing transition to fully electronic interbank check collection and return.

According to the CFPB’s spring 2017 Unified Agenda, it plans to finalize the Fed’s proposed changes to Regulation CC soon.

“Thus, we urge the CFPB to immediately adjust its rulemaking schedule and re-propose changes for public input that will be more relevant than that received in 2011,” the letter reads.

Additional information, including a link to the letter, can be found on CUNA’s Removing Barriers Blog.