NAFCU urges CFPB to exempt CUs from adopted regulations

WASHINGTON, DC (June 19, 2018) — National Association of Federally-Insured Credit Unions (NAFCU) Regulatory Affairs Counsel Kaley Schafer today sent a letter to the Consumer Financial Protection Bureau (CFPB), urging the bureau to use its exemption authority to exclude credit unions from certain rules that were meant for larger financial institutions in order to provide the industry with regulatory relief. The association also recommended that the bureau review and eliminate outdated requirements.

“The adopted regulations include rulemakings adopted under Federal consumer financial law, as well as those laws that were adopted pursuant to specific requests by Congress,” Schafer wrote. “NAFCU has previously commented on these adopted regulations and urges the Bureau to look at the impacts these regulations have on credit unions. NAFCU specifically urges the Bureau to review and eliminate outdated requirements, and those that are unduly burdensome.”

Specifically, Schafer recommended the bureau:

  • include government-sponsored enterprise (GSE) loans as a permanent category under the qualified mortgage safe harbor exemption;
  • revise the qualified mortgage’s definition regarding the debt-to-income ratio;
  • clarify integrated mortgage disclosure rules to ensure accurate information is provided to consumers;
  • extend the mortgage servicing rule’s small servicer exemption to exclude successors in interest and force-placed hazard insurance requirements;
  • increase the mortgage servicing rule’s grace period for servicers to halt foreclosure proceedings when loss mitigation applications have been filed;
  • revise the broad definition of loan originator;
  • exclude credit unions from the remittance transfer rule, or alternatively, increase the number of transfers allowed under the safe harbor exemption;
  • rescind the prepaid accounts rule in its entirety, or exclude credit unions from the rule;
  • exclude credit unions from debt collection rulemakings;
  • exclude credit unions from required small business lending data collection under the Equal Credit Opportunity Act; and
  • exempt credit unions from any rulemaking regarding access to financial records.

Schafer sent the letter in response to the bureau’s request for information (RFI) on its adopted regulations, which include the rulemaking authorities given to the bureau by the Dodd-Frank Act and the rules it has issued since its creation in 2011.

For full text of the letter, click here.


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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