NAFCU, others offer support bill to streamline CFPB’s guidance

WASHINGTON, DC (June 12, 2018) — The National Association of Federally-Insured Credit Unions (NAFCU), along with more than a dozen other financial services industry trade groups, offered support for legislation that would require the CFPB to issue timely guidance on its rules in order to facilitate industry compliance and better protect consumers.

The groups sent a letter Monday to House Financial Services Subcommittee Chairman Sean Duffy, R-Wis., and Rep. Ed Perlmutter, D-Colo., thanking them for introducing the Give Useful Information to Define Effective (GUIDE) Compliance Act (H.R. 5534).

“Market participants continue to be frustrated by CFPB guidance that contains caveats which serve to diminish the reliability of said regulation for future reference,” the letter states. “The Bureau has been historically slow to issue guidance, which has created an environment of uncertainty amongst all stakeholders.”

The groups highlight the lack of clarity around the bureau’s “Know Before You Owe (KBYO)” rule and the resulting consequences for consumers and financial institutions.

Specifically, the letter offers support of the bill’s provisions to:

  • set clear timelines for the CFPB to solicit industry questions and provide answers during and after the implementation process;
  • require public notice before the bureau amends or revokes guidance;
  • eliminate liability for acts that were consistent with guidance when they occurred, regardless of whether that guidance has since changed; and
  • require the bureau to develop published guidelines for determining the size of any civil money penalties.

NAFCU has repeatedly asked that the CFPB adopt a guidance process similar to other regulators where regulated entities can seek answers on unresolved or unclear issues. More guidance is needed from the bureau that articulates clear supervisory expectations so credit unions have the information they need to operate in a safe, sound and compliant manner.


The National Association of Federally-Insured Credit Unions is the only national trade association focusing exclusively on federal issues affecting the nation’s federally-insured credit unions. NAFCU membership is direct and provides credit unions with the best in federal advocacy, education and compliance assistance. For more information on NAFCU, go to or @NAFCU on Twitter.


Marisol Garibay
Vice President, Communications & Media Relations
National Association of Federally-Insured Credit Unions
3138 10th Street North
Arlington, VA 22201
O: (703) 842-2820 ext. 291

Amanda Dela Cruz
Associate Director, Communications
National Association of Federally-Insured Credit Unions
3138 10th Street North
Arlington, VA 22201
O: (703) 842-2263 ext. 263
M: (571) 447-0022

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