Comments on NCUA, CFPB proposals due in March

March 4, 2015

WASHINGTON (3/5/15)--Comments on regulatory proposals from the National Credit Union Administration and the Consumer Financial Protection Bureau (CFPB) are due to the agencies in March. CUNA is also collecting comments from stakeholders on a number of the proposals, in order to inform its own advocacy positions.

Comment deadlines in March include:

  • March 16 (comments due to CUNA March 9): CFPB amendments to 2013 mortgage rules under the Real Estate Settlement Procedures Act and Truth in Lending Act. The proposal covers nine major topics: successors in interest, definition of delinquency, requests for information, force-placed insurance, early intervention, loss mitigation, prompt payment crediting, periodic statements and small servicer definition;
  • March 19: NCUA Economic Growth and Regulatory Paperwork Reduction Act regulatory review. Comments on unnecessary, outdated or burdensome regulatory requirements imposed on federal credit unions on one-third of the agency's rules and regulations;
  • March 23 (comments due to CUNA by March 9): CFPB proposed rule on prepaid accounts. The bureau's proposal would extend consumer protections to prepaid accounts, including those that offer credit options;
  • March 27 (comments due to CUNA by March 20): NCUA capital planning and stress-testing schedule shift. The agency has proposed to change the timing of certain requirements in the capital planning and stress-testing cycle, as well as change the definition of "covered credit union" and the addition of a definition for "capital planning process;"
  • March 30 (comments due to CUNA by March 9): CFPB Safe Student Account Scorecard. The bureau has proposed a draft scorecard that offers information to colleges and universities when soliciting agreements from financial institutions and is seeking input on material schools can choose to include; and
  • March 30 (comments due to CUNA by March 16): CFPB proposal regarding "rural" and "underserved" areas. The bureau is proposing changes regarding small creditors and rural and underserved areas under Truth in Lending requirements relating to escrow requirements for higher-priced mortgage loans.