CUNA continues push for BCFP guidance on S. 2155 provisions

October 2, 2018

CUNA applauds NCUA’s timely implementation of provisions in the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) and continues to await fulfillment of several provisions by the Bureau of Consumer Financial Protection. CUNA wrote to the Senate Banking Committee Tuesday for the record of its hearing on implementation of S. 2155, which was strongly supported by CUNA and signed into law in May.

“CUNA further awaits the consumer protection-related provisions to be fulfilled by the Bureau of Consumer Financial Protection, specifically relating to the Home Mortgage Disclosure Act, the Truth in Lending Act Qualified Mortgage requirements, and the Truth in Lending Act-Real Estate Settlement Procedures Act (TILA-RESPA) Integrated Disclosures (TRID),” wrote CUNA President/CEO Jim Nussle. “Guidance in these areas would be welcomed sooner rather than later.”

CUNA’s letter also notes:

  • CUNA applauds NCUA for its quick implementation of the removal of one-to-four-unit non-owner occupied residential loans from credit unions' member business lending cap; 
  • As S. 2155 provisions comparing what was the Making Online Banking Initiation Legal and Easy (MOBILE) Act relating to data privacy and record retention are implemented by federal banking agencies, CUNA expects some degree of guidance from NCUA about how it may impact credit union examinations; and
  • CUNA continues to oppose NCUA’s efforts to seek additional authority to examine and regulate credit union service organizations and third-party vendors. CUNA believes NCUA has effectively managed this risk within its current regulatory authority.