Regulatory agencies routinely solicit feedback from the entities they regulate when considering rule proposals. The League values these opportunities to ensure that Ohio's credit unions' voices are heard and that our system of financial cooperatives and the members that rely on it are protected. Therefore, we appreciated the opportunity to opine on regulatory proposals from the National Credit Union Administration (NCUA) and the Consumer Financial Protection Bureau (CFPB).
- Mortgage servicing rights (NCUA): The NCUA proposed to amend its investment regulation to permit federal credit unions (FCUs) to purchase mortgage servicing rights from other federally insured credit unions under certain conditions. Under the proposed rule, eligible FCUs may purchase the mortgage servicing rights of loans that the FCU is otherwise empowered to grant, provided these investments are consistent with safety and soundness and made in accordance with the FCU's policies and procedures that address the risk of these investments and servicing practices. The League supported this NCUA proposal and agreed that safety and soundness considerations were appropriate when considering the complexity of purchasing and administering mortgage servicing rights. Please find the League's comment letter here.
- Consumer access to financial records (CFPB): Section 1033 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) provides, among other things, that subject to rules prescribed by CFPB, a consumer financial services provider, must make available to a consumer, information in the control or possession of the provider concerning the consumer financial product or service that the consumer obtained from the provider. The Bureau issued an Advance Notice of Proposed Rulemaking (ANPR) to solicit comments and information to help the Bureau develop regulations to implement section 1033. Although the League agrees with the concept of making it easier for consumers to stay informed about their financial information, we believe it is in the best interests of credit unions and their members to make sure their financial information is protected to the greatest extent possible. Additionally, we believe credit unions should enjoy a certain level of protection when data breaches occur due to a third party. Please find the League's comment letter here.
If you have further questions or concerns about the aforementioned NCUA or CFPB requests for comment, please contact League Regulatory Counsel Chris Noble, Esq.