CUNA: BCFP should assist CUs w/ rule implementation

July 2, 2018

The Bureau of Consumer Financial Protection has several ways in which it can assist the credit union industry in complying with regulatory requirements, CUNA wrote in its comprehensive white paper to the bureau. CUNA submitted a copy of its white paper in response to the bureau’s request for information on guidance and implementation support.

“The past several years has seen a massive increase in consumer financial services regulations. The increase in regulations is particularly burdensome for credit unions which, unlike massive banks, do not have dozens of legal experts in house to assist with compliance questions,” reads the white paper.

To enhance the bureau’s ability to assist the industry with consumer financial services rules and requirements, CUNA recommends the bureau:

  • Accept inquiries regarding compliance with its regulations and guidance by telephone, email, or through its website, and responses should be provided by bureau staff within 24-48 hours of receiving the inquiry;
  • Track questions it receives from the industry, and use those questions to make annual adjustments to regulations or commentaries to address ambiguities;
  • Publish written guidance or Frequently Asked Questions with written interpretations to assist industry stakeholders on regulatory implementation;
  • Conduct interactive webinars on proposed and final rulemakings that should provide information about regulatory requirements and practical examples of how to comply with new requirements and allow for questions and answers;
  • Provide both comprehensive final rule summaries and short one-page summaries for final rules. When possible, CUNA strongly encourages the bureau to provide flow charts that illustrate how to comply with various regulations
  • Place all its compliance resources, including recorded webinars, final rule summaries and FAQ documents, in a central location on its website for easy and quick access;
  • Frequently update compliance guides on its website so industry stakeholders always have the most recent information accessible; and
  • Conduct annual outreach with industry stakeholders, especially credit unions, to receive feedback on its current compliance resources and what additional resources would be helpful to the industry.