Transparency, flexibility needed from CFPB during pandemic

March 18, 2020

CUNA President/CEO Jim Nussle followed up his Tuesday conversation with Consumer Financial Protection Bureau (CFPB) Director Kathy Kraninger with a Wednesday letter to her outlining ways the CFPB could help credit unions more efficiently serve members affected by the coronavirus (COVID-19) pandemic.

“We ask that the CFPB stay in regular communication with financial services providers and be as transparent as possible during this crisis. If up-to-date information from official sources becomes infrequent, then regulated entities may in turn become concerned that looming issues are being ignored or not adequately addressed,” the letter reads. “ CUNA is ready and willing to assist in communicating and amplifying any critical messages from the Bureau to credit unions and their members…We also encourage the CFPB to use its platform to assure consumers that their deposits are insured by the federal government and they can continue to look to their local credit union for financial guidance and assistance.”

CUNA wrote to the CFPB last week noting how finalizing the Remittance Rule changes and providing an accommodation for transfers sent to individuals abroad affected by the COVID-19 outbreak would ensure credit union members have access to efficient methods from their local credit union to transfer money internationally to relatives and friends affected by the pandemic.

Anticipating a likely short-staffing issue, CUNA recommends the CFPB act to provide flexibility for credit unions’ regulatory compliance responsibilities to ensure consumers are still able to access financial products and services if staff resources become in short supply.

These recommendations include:

  • Avoid finalizing or implementing any new rules or initiatives that would add to burden or strain compliance resources;
  • Reduce onsite routine examinations so that credit union employees are not required to be in the office for unnecessary lengths of time and can dedicate their work time to focusing on serving members;
  • Consider pushing back or providing extensions for any 2020 filing deadlines, including Home Mortgage Disclosure Act reporting, credit card account agreement reporting, and others;
  • Adopt a policy of “good faith efforts toward substantial compliance” during the compliance examination process once routine examinations resume after the pandemic;
  • Allow consumers to temporarily waive disclosure timing-requirements under the TILA-RESPA Integrated Disclosure (TRID) rule (e.g. the three-day closing disclosure requirement); and
  • Provide temporary flexibility for disclosures and application processing timelines related to loss mitigation efforts, especially for COVID-19 related loan modifications, forbearance agreements, and repayment plans.