No summer break for federal regulators
Published by: Sean Brown
July 27, 2022 | Regulatory
Just like the Ohio weather, federal rulemaking is also heating up this summer. Various federal regulatory proposals could impact how your credit union serves its members. Ohio’s credit unions already lead the way in efficient, innovative, and member-focused financial services; thus, the League is looking to submit comment letters advocating for what allows you to do what you do best: serve over 3.1 million members.
FTC Telemarking Sales Rules
The Federal Trade Commission (FTC) issued a notice of proposed rulemaking that would require telemarketers and sellers to maintain additional records of their telemarketing transactions and prohibit material misrepresentations and false or misleading statements in business-to-business (“B2B”) telemarketing transactions. Additionally, as part of this review, the FTC issued an advanced notice of proposed rulemaking regarding whether the rule should continue to exempt telemarketing calls to businesses, whether the rule should require a notice and cancelation mechanism with negative option sales, and whether to extend the rule to apply to telemarketing calls consumers initiate to a telemarketer. Comments for either proposal are due Aug. 2.
FTC Motor Vehicle Dealers Trade Regulations
Additionally, the FTC issued a notice of proposed rulemaking related to the sale, financing, and leasing of motor vehicles by motor vehicle dealers. The proposed rule seeks to further curtail deceptive and harmful practices used in vehicle transactions. Several Ohio credit unions and their members have experienced various direct lending challenges in a strained economy, so the League will submit a comment letter and encourage credit unions to submit comments illustrating their members’ experiences. Comments are due no later than Sept. 12.
FinCEN No-Action Letter Process
FinCEN issued an advance notice of proposed rulemaking (ANPRM) to solicit public comment on questions relating to the implementation of a no-action letter process at FinCEN. Currently, FinCEN does not have a “no-action letter” process and is seeking input as to whether one should be implemented, and if so, how the process should interact with other forms of relief. The League has always advocated against duplicative, unnecessary forms of enforcement, and plans to do so here. All comments are due Aug. 5.
NCUA Regulatory Review
The National Credit Union Administration (NCUA) conducts a regulatory review of all existing regulations every three years. This year, the NCUA is focusing on Sections 700 – 710. The League is currently evaluating the sections up for review and collecting feedback from credit unions on which sections should be changed and why. If you have a particular interest in a section or would like to comment, all comments are due Aug. 16.
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.