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CUNA backs legislation to remove credit union barriers in U.S. House and Senate
WASHINGTON, D.C. (March 16, 2015) – CUNA sent letters of support today for legislation that would remove barriers for credit unions and foster service excellence for their members. CUNA supports S. 423, the Privacy Notice Modernization Act; S. 482, the Consumer Financial Protection Bureau Examination and Reporting Threshold Act; and H.R. 1265, the Bureau Advisory Commission Transparency Act.
- The Privacy Notice Modernization Act will make privacy notices sent to consumers by financial institutions more meaningful by eliminating the requirement that the notices be sent annually, and requiring them only to be sent when the privacy policy of the financial institution has changed.
- The Consumer Financial Protection Bureau Examination and Reporting Threshold Act would raise the CFPB examination threshold from $10 billion in total assets to $50 billion. While there are only a small number of credit unions subject to the cap today, we believe raising the cap beyond the asset size ceiling would important recognition that credit unions were not the cause or perpetrators of the financial crisis and that credit unions, regardless of size, have a different incentive structure than for-profit financial institutions because they are owned by those they serve.
- The Bureau Advisory Commission Transparency Act clarifies that the Federal Advisory Committee Act (Pub L. No. 92-463) applies to the Consumer Financial Protection Bureau (CFPB). This legislation would, in effect, open Bureau advisory committee meetings to the public.
See the full letters below:
March 16, 2015
The Honorable Jerry Moran The Honorable Heidi Heitkamp
United States Senate United States Senate
361A Russell Senate Office Building 502 Hart Senate Office Building
Washington, D.C. 20510 Washington, D.C. 20510
Dear Senators Moran and Heitkamp:
On behalf of the Credit Union National Association (CUNA), I am writing in support of S. 423, the Privacy Notice Modernization Act. CUNA is the largest credit union advocacy organization in the United States, representing nearly 90% of America’s 6,500 state and federally chartered credit unions and their 102 million members. CUNA strongly supports this legislation and appreciates your continued leadership on this issue.
Consumers are rightfully concerned about the protection of their personal financial information, and it is important for them to understand how their financial institutions handle this information. The Privacy Notice Modernization Act will make privacy notices sent to consumers by financial institutions more meaningful by eliminating the requirement that the notices be sent annually, and requiring them only to be sent when the privacy policy of the financial institution has changed. In addition to enhancing the value of these privacy notifications for consumers, your legislation also reduces regulatory burden for credit unions.
This legislation has enjoyed broad bipartisan support. It passed the House of Representatives by voice vote in both the 112th and 113th Congresses. Last Congress, it had 76 bipartisan cosponsors in the Senate. We look forward to its consideration during this Congress and to working with you to see its enactment. On behalf of America’s credit unions, thank you very much for your leadership on this matter.
Sincerely,
Jim Nussle
President & CEO
March 16, 2015
The Honorable Patrick Toomey The Honorable Joe Donnelly
United States Senate United States Senate
248 Russell Senate Office Building 720 Hart Senate Office Building
Washington, D.C. 20510 Washington, D.C. 20510
Dear Senators Toomey and Donnelly:
On behalf of the Credit Union National Association (CUNA), I am writing in support of S. 482, the Consumer Financial Protection Bureau Examination and Reporting Threshold Act. CUNA is the largest credit union advocacy organization in the United States, representing nearly 90% of America’s 6,500 state and federally chartered credit unions and their 102 million members. CUNA strongly supports this legislation and appreciates your continued leadership on this issue.
- 482 would raise the CFPB examination threshold from $10 billion in total assets to $50 billion. While there are only a small number of credit unions subject to the cap today, we believe raising the cap beyond the asset size ceiling would important recognition that credit unions were not the cause or perpetrators of the financial crisis and that credit unions, regardless of size, have a different incentive structure than for-profit financial institutions because they are owned by those they serve. For these reasons, we believe the legislation could be even stronger if it included a provision providing for automatic adjustment of the threshold indexed for inflation.
There is additional public policy merit to raising this threshold: it would cause the Bureau to focus its resources more directly on the larger institutions and those that were previously unregulated, while still ensuring the examination of the institutions that serve the greatest number of consumers. While this change would not significantly change the number of institutions and percentage of assets presently subject to examination by the Bureau, it would allow the Bureau to more efficiently use its examination resources in the coming years. The number of financial institutions approaching $10 billion in total assets is increasing. As these institutions cross the threshold, the Bureau will be required to spend more of its resources examining these newly covered institutions at the expense of other important consumer protection activities.
Institutions affected by S. 432 would continue to be subject to the Bureau’s rules and regulations, and they would be examined for compliance with these rules by their prudential regulator. In addition, Section 1026 of the Dodd-Frank Act provides the Bureau authority to examine on a sampling basis credit unions, thrifts and banks for which it does not have examination authority and includes language directing coordination between the prudential regulators and the Bureau.
We look forward to the consideration of this bill during this Congress and to working with you to see its enactment. On behalf of America’s credit unions, thank you very much for your leadership on this matter.
Sincerely,
Jim Nussle
President & CEO
March 16, 2015
Representative Sean Duffy
Member of Congress
U.S. House of Representatives
Washington, D.C. 20515
Dear Representative Duffy:
On behalf of the Credit Union National Association (CUNA), I am writing in support of legislation you introduced H.R. 1265, the “Bureau Advisory Commission Transparency Act.” CUNA is the largest credit union advocacy organization in the United States, representing nearly 90% of America’s 6,300 state and federally chartered credit unions and their 102 million members.
This legislation clarifies that the Federal Advisory Committee Act (Pub L. No. 92-463) applies to the Consumer Financial Protection Bureau (CFPB). This legislation would, in effect, open Bureau advisory committee meetings to the public.
While not required to do so by Congress, the Bureau established a Credit Union Advisory Council (CUAC). This group meets four times a year, and at least half of the meetings may be in person at the Bureau headquarters. These meetings are not open to the public. However, we feel these meetings should be open to public observation as they provide an important forum for credit union representatives to share concerns and provide practical guidance to the agency on operational and public policy issues.
On behalf of America’s credit unions and their 102 million members, thank you very much for introducing this legislation. We look forward to working with you to secure its enactment.
Sincerely,
Jim Nussle
President & CEO