League advocacy keeping pace with federal rulemaking

Published by: Sean Brown

March 23, 2022 | Regulatory

Over the past few months, federal regulators have cranked out various proposals that could impact how your credit union serves its members. As prudentially regulated financial cooperatives, Ohio credit unions already serve as an example of how financial institutions can responsibly and competitively operate under the current regulatory scheme, so the League prepared several comment letters and called you to act on behalf of Ohio’s 3.1 million members through the recent advocacy efforts:

CFPB “Junk Fees”
In early February, the CFPB issued an overly broad request for information (RFI) related to fees that are not subject to competitive processes to assist the agency and policymakers in creating fairer, more transparent, and competitive consumer financial markets. As the League finalizes a comment letter combatting the narrative that service fees are “junk fees,” we need your help. Reach out to the CFPB with your credit union’s data, experiences, and use of service fees through a formal comment letter. All comments are due March 31, 2022, and you can use this League-provided template to get started.

NCUA Succession Planning
A day later in February, the NCUA Board announced a proposed rule requiring all federally-charted credit union (FCU) boards of directors to establish and adhere to a succession plan at their discretion. The League is providing formal comment cementing the proposition that the decision-making authority over the day-to-day operations of credit unions is best left to the credit unions themselves, not federal regulators. All comments are due April 4, 2022, so there is still time to submit your own comment.

CFPB Buy Now, Pay Later (BNPL)
Lastly, the CFPB issued a request for comment seeking information on buy now, pay later (BNPL) products. Credit unions already comply with stringent lending requirements and need to compete with fintechs on innovative consumer solutions on a level regulatory playing field. The League will be submitting its own comment, but if you have experience with BNPL products or would like to comment on the proposal, comments are due March 25, 2022.

If you want to learn more about our advocacy efforts or have questions about a specific regulatory proposal, don’t hesitate to reach out to League Regulatory Affairs Director Sean Brown.

Contact Sean Brown for questions or assistance.

Sean Brown
Sean Brown Director, Regulatory Affairs E: sbrown@ohiocul.org
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