CUNA wrote to the Senate Banking, Housing, and Urban Affairs Committee prior to the committee hearing semiannual testimony from Fed Vice Chair for Supervision Randal Quarles. The letter discussed how a proposed Federal Reserve regulation could adversely impact credit unions by increasing regulatory burden.
The Board’s proposed updates to Regulation II (12 C.F.R. pt. 235) seek to provide “clarification” to the regulation of debit card routing requirements. In our view, the proposal represents much more than a clarification, instead adding new requirements to Regulation II that would increase the complexity and costs associated with debit cards. CUNA plans to provide fulsome comments to the Board detailing credit unions concerns; nonetheless, it is appropriate for the Committee in its oversight role to explore the proposed rule and its implications with Vice Chairman Quarles.
CUNA wrote to the House Small Business Committee prior to a hearing entitled, An Examination of the SBA’s Covid-19 Programs. The letter stated that Congress should hold the SBA accountable for blocking privately insured credit unions from accessing PPP funding. Despite the passage of the PPP and Health Care Enhancement Act, which included all state and federally chartered credit unions in the definition of “credit union,” certain credit union PPP applications were not addressed in a timely manner.
The letter also calls for the SBA to provide certainty for backlogged PPP loan forgiveness applications. SBA is required by its own Interim Final Rule to issue a decision within 90 days after receiving the application.
Annual Advocacy Priorities
The ongoing foundation for CUNA's credit union advocacy efforts focuses on the areas below, which represent the input and guidance shared from credit unions across the country.
Consumer Protection - Credit unions are the original consumer protectors in the financial services sector; commonsense consumer protection regulation recognizes that our structure and mission makes us different.
Examination & Supervision - Credit unions support a regulatory scheme that minimizes the adverse business impact of regulations on credit union operations while ensuring that credit unions operate safely and soundly while providing cooperative financial products and services.
Charter Enhancement - Improving both the Federal Credit Union Act and state credit charters is at the top of the agendas of CUNA and the state credit union leagues. We are seeking to reduce the regulatory burdens of credit unions and empower credit unions with increased authorities and greater flexibility to serve their members.
Tax Issues - Credit unions are democratically owned and controlled not-for-profit cooperative financial institutions that take pride in their “People Helping People” philosophy. Credit unions are exempt from federal income tax because of their structure as not-for-profit financial cooperatives and their mission to promote thrift and provide access to credit for provident purposes.
Mortgage Lending & Housing - Credit union mortgage lending is a vital path to homeownership for millions of American families, and credit unions need commonsense regulation of consumer-friendly credit union mortgage products and fair and equitable access to a robust secondary market to fulfill their role in our nation's housing market.
Regulatory Relief - For many Americans, credit unions are their opportunity for affordable financial services, but regulatory burden continues to provide challenges to credit unions and their members. Unfortunately, credit union members end up paying the price for regulatory burden.
Credit Union Powers - The rationale for expanded credit union powers is quite simple: credit union powers are based on their not-for-profit, member-owned, and community-based structure. Because credit union members own their financial institutions, the decisions credit unions make reflect the needs and interests of their memberships. This member-control is the basis for providing credit unions with wide authority to serve their members.
Payments & Technology - Credit unions need to have access to the latest technology to ensure their ability to provide important services to members. Regulations and other requirements need to be appropriate for the size and sophistication of a credit unions operations.