Enhance BCFP w/ transparent and consistent enforcement

WASHINGTON, DC (July 2, 2018) — With the recent increase in consumer regulations on financial institutions, the Bureau of Consumer Financial Protection opened its series of requests for information (RFI) seeking feedback on performance. Credit Union National Association (CUNA) is strongly encouraging the Bureau of Consumer Financial Protection (BCFP) to assist the credit unions in complying with regulatory requirements.

“The increase in regulations is particularly burdensome for credit unions which, unlike massive banks, do not have dozens of legal experts in house to assist with compliance questions,” the white paper reads. “There are, however, ways in which the Bureau can assist the industry in complying with consumer financial services regulatory requirements.”

CUNA outlined the following recommendations to ensure the Bureau’s enforcement is transparent and consistent:

  • Accept inquiries regarding compliance with its regulations and guidance by telephone, email, or through its website, and responses should be provided by bureau staff within 24-48 hours of receiving the inquiry;
  • Track questions it receives from the industry, and use those questions to make annual adjustments to regulations or commentaries to address ambiguities;
  • Publish written guidance or Frequently Asked Questions with written interpretations to assist industry stakeholders on regulatory implementation;
  • Conduct interactive webinars on proposed and final rulemakings that should provide information about regulatory requirements and practical examples of how to comply with new requirements and allow for questions and answers;
  • Provide both comprehensive final rule summaries and short one-page summaries for final rules. When possible, CUNA strongly encourages the bureau to provide flow charts that illustrate how to comply with various regulations
  • Place all its compliance resources, including recorded webinars, final rule summaries and FAQ documents, in a central location on its website for easy and quick access;
  • Frequently update compliance guides on its website so industry stakeholders always have the most recent information accessible; and
  • Conduct annual outreach with industry stakeholders, especially credit unions, to receive feedback on its current compliance resources and what additional resources would be helpful to the industry.

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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