CUNA discusses improvements to enforcement in CFPB comment letter

May 15, 2018


CONTACT: Lauren Williams – CUNA Communications; (202) 626-7642;             

Washington, DC (May 14, 2018) – Credit Union National Association (CUNA) filed this comment letter in response to the Bureau of Consumer Financial Protection's (CFPB) latest Request for Information (RFI) on enforcement processes.  

The letter addresses several improvements that the Bureau should make. Specifically, CUNA recommends that the Bureau delegate to the National Credit Union Administration (NCUA) primary examination and enforcement of consumer protection laws for credit unions with over $10 billion in assets.  

“CUNA supports [transferring examination and enforcement authority] as it will enable the bureau to fully focus its examination and enforcement efforts on Wall Street banks and other abusers of consumers, while ensuring credit unions continue to be adequately supervised by the federal agency most proficient with its structure and operation,” the letter reads.  

Should the bureau retain examination and enforcement over credit unions with over $10 billion in assets, CUNA stresses the importance of synergy with the NCUA as a partner throughout the investigation and enforcement process.  

The additional considerations mentioned in the letter were: 

  • The bureau must not impose enforcement actions that are not supported by prescriptive laws, regulations, or guidance under its jurisdiction; 
  • If the bureau continues primary examination and enforcement over the largest credit unions, then its processes must be more transparent and directed at resolving any violations, with enforcement actions serving as a last resort; and  
  • The bureau should establish for the financial services industry a matrix for how it determines civil money penalties. This matrix should be published for notice and comment. 

About CUNA   
Credit Union National Association (CUNA) is the only national association that advocates on behalf of all of America’s credit unions, which are owned by 110 million consumer members. CUNA, along with its network of affiliated state credit union leagues, delivers unwavering advocacy, continuous professional growth and operational confidence to protect the best interests of all credit unions. For more information about CUNA, visit