NAFCU letter in conjunction with tomorrow’s House Judiciary Committee Hearing: reduce reg burden

February 10, 2014

The Honorable Bob Goodlatte
Judiciary Committee
United States House of Representatives
Washington, D.C. 20515

The Honorable John Conyers
Ranking Member
Judiciary Committee
United States House of Representatives
Washington, D.C. 20515

Re: The Need for Regulatory Relief for Our Nation’s Credit Unions

Dear Chairman Goodlatte and Ranking Member Conyers:

On behalf of the National Association of Federal Credit Unions (NAFCU), the only trade association exclusively representing the interests of our nation’s federally chartered credit unions, I write today in conjunction with tomorrow’s legislative hearing on the Searching for and Cutting Regulations that are Unnecessarily Burdensome (SCRUB) Act of 2014. Credit unions and their 97 million members strongly support efforts to ensure that all federal agencies, including those with direct jurisdiction over credit unions including the National Credit Union Administration (NCUA) and Consumer Financial Protection Bureau (CFPB), appropriately consider the impact of their rules and regulations.

As you know, this important piece of legislation would establish a commission to review federal regulations and identify those that should be repealed or amended to reduce unnecessary regulatory burdens. In addition, the bill would require agencies to offset the cost of new regulations by repealing or amending regulations identified by the commission. NAFCU supports the intention of regulatory relief behind this draft legislation and believes it would be a good first step in addressing the overly burdensome regulatory environment credit unions face.

All community based financial services institutions, including credit unions, are struggling under an ever-increasing regulatory burden. The impact of this growing compliance burden is evident as the number of credit unions continues to decline, dropping by more than 700 institutions since 2009. Credit unions didn’t cause the financial crisis and shouldn’t be caught in the crosshairs of regulations aimed at those entities that did. Unfortunately, that has not been the case thus far as all credit unions are subject to rule writing authority of the new CFPB. Accordingly, finding ways to cut-down on burdensome and unnecessary regulatory compliance costs is a chief priority of our members. As evidence by the bill before you today, it is clearly a priority of the Judiciary Committee.

As outlined in the attached letter sent to Congress in February 2013, NAFCU’s five point plan for regulatory relief includes several important provisions aimed at ensuring credit unions aren’t subject to over burdensome, outdated, or duplicative regulation. As the Judiciary Committee continues to look at ways to reduce regulatory burden moving forward, we ask that you keep in mind the need for regulatory relief for our nation’s credit unions.

Thank you for the opportunity to provide additional information with respect to the overwhelming amount of regulatory burden credit unions face. We look forward to the committee’s review of the need for regulatory relief and stand ready to provide additional input should the committee have questions about regulatory burden facing small financial institutions such as credit unions.

If my colleagues or I can be of assistance to you, or if you have any questions regarding this issue, please feel free to contact myself, or NAFCU’s Director of Legislative Affairs, Jillian Pevo at (703) 842-2836.


Brad Thaler
Vice President of Legislative Affairs

cc:        Members of the House Judiciary Committee

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