NAFCU letter in advance of tomorrow’s hearing, “The Dodd-Frank Act and Regulatory Overreach”

(May 13, 2015) — 

The Honorable Sean Duffy
Subcommittee on Oversight and Investigations House Financial Services Committee
U. S. House of Representatives
Washington, DC 20515

The Honorable Al Green
Ranking Member
Subcommittee on Oversight and Investigations House Financial Services Committee
U. S. House of Representatives
Washington, DC 20515

Re:  Tomorrow’s Hearing: “The Dodd-Frank Act and Regulatory Overreach”

Dear Chairman Duffy and Ranking Member Green:

On behalf of the National Association of Federal Credit Unions (NAFCU), the only trade association exclusively representing the interests of our nation’s federal credit unions, I write in advance of tomorrow’s hearing, “The Dodd-Frank Act and Regulatory Overreach.”  NAFCU appreciates the subcommittee holding this important hearing on the aftermath of Wall Street reform.

In the wake of financial reform, credit unions have seen an increasingly difficult and challenging regulatory environment.  This growing demand on credit unions is demonstrated by a 2011 NAFCU survey of our membership that found that nearly 97% of respondents were spending more time on regulatory compliance issues than they did in 2009.  A 2012 NAFCU survey of our membership found that 94% of respondents had seen their compliance burdens increase since the passage of the Dodd-Frank Act in 2010. Furthermore, a 2013 NAFCU survey of our members found that nearly 27% had increased their full-time equivalents (FTEs) for compliance personnel in 2013, as compared to 2012. That same survey found that over 70% of respondents had non-compliance staff members take on compliance-related duties due to the increasing regulatory burden. This highlights the fact that many non-compliance staff are being forced to take time away from serving members to spend time on compliance issues.

Credit unions are struggling with the new regulatory burdens in a post Dodd-Frank world.  Since the second quarter of 2010, we have lost 1,200 federally-insured credit unions, 96% of which were smaller institutions below $100 million in assets.  Many smaller institutions simply cannot keep up with the new regulatory tide and have had to merge out of business or be taken over.

While it was important to go after the bad actors that caused the financial crisis, many of the good actors, such as credit unions, have been caught up in the tidal wave of new regulations post-crisis.  It is with this in mind that NAFCU continues to call on Congress to enact commonsense regulatory relief that will enable credit unions to better serve their 100 million member-owners.  We urge Congress to act on the ideas found in NAFCU’s five-point plan on regulatory relief which we shared with you earlier this year (attached).

Thank you for holding this important hearing.  If you have any questions or would like further information about any of these issues, please do not hesitate to contact me or NAFCU’s Director of Legislative Affairs Jillian Pevo by telephone at (703) 842-2836 or by e-mail at


Brad Thaler

Vice President of Legislative Affairs

cc:       Members of the House Financial Services Subcommittee on Oversight and Investigation

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