CUNA recommends improvements to adjudications process in letter to CFPB

WASHINGTON, DC (May 4, 2018) — The Credit Union National Association (CUNA) offered comments in a letter to the Bureau of Consumer Financial Protection (CFPB) seeking improvement to their Rules of practice for Adjudication Proceedings. The letter was written in response to the Bureau’s latest Request for Information (RFI) to assess its functions.

Under the authorization of the Consumer Financial Protection Act, the Bureau must conduct administrative adjudications in compliance with the Administrative Procedure Act. The Bureau may file an administrative Notice of Charges only to enforce agreement with the Consumer Financial Protection Act and related laws.

Specifically, CUNA respectfully urged the Bureau to address following concerns:

  • The CFPB should issue a rule mandating that the statutes of limitations for Administrative Adjudications be the same as for federal court proceedings;
  • Rule 206 governing the Bureau’s file disclosure can be unfair in practice and should be amended;
  • Rule 110 does not prevent Bureau employees from providing ex parte information to the Bureau Director during the pendency of the adjudication and this should be changed; and
  • Rule 119 regarding confidentiality protections is unwieldly and could result in unwarranted disclosure of confidential information.

About CUNA

Credit Union National Association (CUNA) is the only national association that advocates on behalf of all of America’s credit unions, which are owned by 135 million consumer members. CUNA, along with its network of affiliated state credit union leagues, delivers unwavering advocacy, continuous professional growth and operational confidence to protect the best interests of all credit unions. For more information about CUNA, visit To find your nearest credit union, visit


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