NAFCU provides input on CFPB’s strategic plan

WASHINGTON, DC (November 17, 2017) — National Association of Federally-Insured Credit Unions (NAFCU) Senior Regulatory Affairs Counsel Michael Emancipator today wrote to the Consumer Financial Protection Bureau (CFPB) outlining nine areas in which the bureau could improve its operations and provide some relief to credit unions. Emancipator was writing in regard to the bureau’s 2018-2022 Strategic Plan.

To provide credit unions with regulatory relief, NAFCU recommends that the CFPB:

  • increase its use of exemption authority;
  • provide clarification around unfair, deceptive or abusive acts and practices (UDAAP);
  • take a cautious approach to any potential first-party debt collection rule;
  • revise the definition of qualified mortgage;
  • make changes to mortgage servicing rule to allow more flexibility;
  • improve its Consumer Complaint Database to verify claims before a credit union’s reputation is unfairly tarnished;
  • expand the threshold related to its remittance rule;
  • limit changes to and provide exemptions from Home Mortgage Disclosure Act (HMDA) reporting; and
  • not proceed with overdraft regulations that would impede credit unions’ programs already in place.

Emancipator notes that this regulatory reform agenda would align with President Donald Trump’s executive orders to identify possible regulations to repeal, replace or modify.



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.


Molly Safreed, (NAFCU)

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