Comment Call Archive:
2011 2010 2009 2008 2007 2006
Comment Calls - 2012
- 12-CC-07 CFPB - Removal of 25% Fee Limitation (Due: 6/11/12)
The Consumer Financial Protection Bureau (CFPB) proposes to amend Regulation Z, which implements the Truth in Lending Act (TILA), and the Official Staff Interpretations (OSI) to the regulation. Regulation Z generally limits the total amount of fees that a credit card issuer may require a consumer to pay with respect to an account, limiting fees to 25% of the credit limit in effect when the account is opened. Regulation Z currently states that this limitation applies prior to account opening and during the first year after account opening. The proposal requests comment on whether to amend Regulation Z to apply the limitation only during the first year after account opening. A copy of the proposed rule can be found here: http://www.gpo.gov/fdsys/pkg/FR-2012-04-12/pdf/2012-8534.pdf. - 12-CC-06 FinCEN - Beneficial Owners CDD (Due: 5/4/12)
FinCEN, after consulting with staffs of various Federal supervisory authorities, is issuing this advance notice of proposed rulemaking (ANPR) to solicit public comment on a wide range of questions pertaining to the development of a customer [member] due diligence (CDD) regulation that would codify, clarify, consolidate, and strengthen existing CDD regulatory requirements and supervisory expectations, and establish a categorical requirement for financial institutions to identify beneficial ownership of their account holders,subject to risk-based verification. The ANPR rule can be found here: http://www.gpo.gov/fdsys/pkg/FR-2012-03-05/pdf/2012-5187.pdf - 12-CC-05 CFPB - Remittance Transfers (Due: 4/9/12)
The Consumer Financial Protection Bureau (CFPB) is proposing to amend Regulation E, which implements the Electronic Fund Transfer Act, and its Official Staff Commentary (OSC). The proposal is related to the January 2012 Final Rule (Final Rule) that implements section 1073 of the Dodd-Frank Wall Street Reform and Consumer Protection Act regarding remittance transfers. The proposal requests comment on whether a safe harbor should be adopted with respect to the phrase “normal course of business” in the definition of “remittance transfer provider” to determine whether a person is covered by the rule.The proposal also requests comment on several aspects of the final rule regarding remittance transfers that are scheduled in advance, including preauthorized remittance transfers. The proposed rule can be found here: http://www.gpo.gov/fdsys/pkg/FR-2012-02-07/pdf/2012-1726.pdf. - 12-CC-04 NCUA - Regulatory Reporting of TDRs (Due: 3/2/12)
NCUA proposes to amend its regulations to require federally insured credit unions (FICUs) to maintain written policies that address the management of loan workout arrangements and nonaccrual policies for loans, consistent with industry practice or Financial Institutions Examination Council (FFIEC) requirements. The proposed rulemaking includes guidelines set forth as an interpretive ruling and policy statement (IRPS) and incorporated as an appendix to the rule that will assist FICUs in complying with the rule, including the regulatory reporting of troubled debt restructured loans (TDR loans or TDRs) in FICU Call Reports.This proposal was offered in response to feedback from the industry and in the spirit of reduced regulatory burden. A copy of this proposed rule can be found here: http://www.gpo.gov/fdsys/pkg/FR-2012-02-01/pdf/2012-2206.pdf. - 12-CC-03 NCUA – Elimination of RegFlex Program (Due: 2/27/12)
NCUA proposes to eliminate the Regulatory Flexibility Program (RegFlex) to provide regulatory relief to Federal credit unions (FCUs). NCUA also proposes to remove or amend related rules to ease compliance burden while retaining certain safety and soundness standards. Those rules pertain to eligible obligations, charitable contributions, nonmember deposits, fixed assets, investments, and member business loans. A copy of this proposed rule can be found here: http://www.gpo.gov/fdsys/pkg/FR-2011-12-28/pdf/2011-33041.pdf. - 12-CC-02 NCUA - Maintaining Access to Emergency Liquidity (Due: 2/21/12)
The NCUA Board (NCUA) requests public comment on the scope and requirements of a regulation to require federally insured credit unions (FICUs) to have access to backup federal liquidity sources for use in times of financial emergency and distressed economic circumstances. NCUA intends to issue a regulation that would require federally insured credit unions, as part of their contingency funding plans, to have access to backup federal liquidity sources for use in times of financial emergency and distressed economic circumstances. The Board is contemplating requiring this access be demonstrated by a credit union in one of four ways: *Becoming a member in good standing of CLF directly; *Becoming a member in good standing of CLF through a corporate credit union; *Obtaining and maintaining demonstrated access to the Discount Window; or *Maintaining a certain percentage of assets in highly liquid Treasury securities. If issued, the regulation would be added to NCUA Part 741 (Requirements for Insurance), so as to apply uniformly to all federally-insured credit unions (FISCUs). Comment is also requested on how such a regulation could be implemented to maximize economic benefit while minimizing regulatory burden on credit unions. - 12-CC-01 NCUA - Loan Participations (Due: 2/21/12)
The NCUA Board requests public comment on its proposal to amend its loan participation regulation and relevant provisions in the eligible obligations rule, as well as the rule governing the purchase of assets and assumption of liabilities. The proposed rule aims to reorganize the current rule and direct its regulatory provisions to the purchase of a loan participation. It would also expand loan participation requirements to federally insured, state-chartered credit unions (FISCUs). A copy of this proposed rule can be found here: http://www.gpo.gov/fdsys/pkg/FR-2011-12-22/pdf/2011-32719.pdf.
Comment Calls - 2011
- 11-CC-27 CFPB - Streamlining of Regulations (Due: 3/5/12)
The Bureau of Consumer Financial Protection (CFPB) is requesting specific suggestions for streamlining regulations it recently inherited from other Federal agencies. This Notice asks the public to identify provisions of the inherited regulations that the CFPB should make the highest priority for updating, modifying, or eliminating because they are outdated, unduly burdensome, or unnecessary. It also seeks suggestions for practical measures to make complying with the regulations easier. A copy of the proposed rule can be found here: http://www.gpo.gov/fdsys/pkg/FR-2011-12-05/pdf/2011-31030.pdf. - 11-26-CC FRB - Regulation D (Due:12/19/11)
The Federal Reserve Board (FRB) requests public comment on proposed amendments to Regulation D, Reserve Requirements of Depository Institutions, to simplify the administration of reserve requirements. The proposed amendments would create a common two-week maintenance period for all depository institutions, create a penalty-free band around reserve balance requirements in place of carryover and routine penalty waivers, discontinue as-of adjustments related to deposit revisions, replace all other as-of adjustments with direct compensation, and eliminate the contractual clearing balance program. A copy of the proposed rule can be found here: http://www.gpo.gov/fdsys/pkg/FR-2011-10-18/pdf/2011-26770.pdf. - 11-CC-25 FTC - COPPA Rule (Due: 12/23/11)
The Commission proposes to amend the Children’s Online Privacy Protection Rule (‘‘COPPA Rule’’ or ‘‘Rule’’), consistent with the requirements of the Children’s Online Privacy Protection Act to respond to changes in online technology, including in the mobile marketplace, and, where appropriate, to streamline the Rule. In addition, the Commission proposes adding a new provision addressing data retention and deletion. A copy of the proposed rule can be found here: http://www.gpo.gov/fdsys/pkg/FR-2011-09-27/pdf/2011-24314.pdf. - 11-CC-24 FinCEN - Electronic Filing of BSA Reports (Due: 11/15/11)
The Financial Crimes Enforcement Network (FinCEN) proposes to require electronic filing of certain Bank Secrecy Act (BSA) reports not later than June 30, 2012 in order to enhance the quality of FinCEN’s electronic data, improve its analytic capabilities in supporting law enforcement requirements and significantly reduce the real costs to the United States Government and ultimately to U.S. taxpayers. Specifically, the proposal would make mandatory the electronic submission of all BSA reports excluding the Report of International Transportation of Currency or Monetary Instruments (CMIR). A copy of the proposed rule can be found here: http://www.gpo.gov/fdsys/pkg/FR-2011-09-16/pdf/2011-23841.pdf - 11-CC-23 NCUA - Credit Union Service Organizations (Due: 9/26/11)
NCUA proposes to amend its credit union service organization (CUSO) regulation to address certain safety and soundness concerns. Specifically, the proposal would do the following: *Require all federally insured credit unions (FISCUs) to include, in their agreements with CUSOs, a requirement that a CUSO submit a financial report directly to NCUA and the appropriate SSA, in the case of a FISCU, at least annually. *Limit a “less than adequately capitalized” FISCU’s aggregate cash outlay to a CUSO, measured on a cumulative basis, to the permissible investment limit in the state in which the FISCU is chartered. *Prohibit all FISCUs from investing in a CUSO unless that CUSO’s subsidiaries also comply with all of the requirements of the CUSO rule and/or laws and rules of the state in which the credit union is chartered, as applicable. A copy of this proposed rule can be found here: http://www.gpo.gov/fdsys/pkg/FR-2011-07-27/pdf/2011-18906.pdf. - 11-CC-23 FRB – Debit Interchange - Interim Final Rule-Fraud Prevention Adjustment (Due: 9/30/11)
This Comment Call is available on CUNA’s website. MCUL decided not to issue a Comment Call in Michigan since the application of the Interim Final Rule applies only to larger institutions ($10B and over). There are no credit unions in Michigan that meet this requirement and only 3 in the country. However, we have added CUNA’s Comment Call to our website so that interested parties may still review the Interim Final Rule and comment if they so desire. - 11-CC-22 FHFA - Qualified Residential Mortgages (Due: 8/1/11)
The Federal Housing Finance Agency (FHFA), along with the Federal banking regulators, have proposed rules to implement the credit risk retention requirements of section 15G of the Securities Exchange Act of 1934, as added by section 941 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Per CUNA: “These rules, if finalized in their current form, are not likely to have a direct impact on credit unions except under unique circumstances, as most of the rules apply directly to securitizers rather than originators. A credit union or credit union service organization (CUSO) is an “originator” unless the institution securitizes a pool of loans or leases into an ABS offering or creates a securities trust to issue the ABS. CUNA is concerned that the QRM proposal will become the standard for most residential mortgage loans, which might curtail mortgage lending by credit unions and preclude some otherwise qualified borrowers from receiving mortgage loans.”CUNA Mutual is conducting a Webinar on Monday, July 18 at 2 p.m. EDT to discuss this important issue. Information regarding the registration can be found here: http://www.pageturnpro.com/Credit-Union-National-Association/28346-NewsWatch-0711_2011/index.html#6 - 11-CC-21 FRB - Remittance Transfers (Due: 7/20/11)
The Federal Reserve Board (FRB) is proposing to amend Regulation E, which implements the Electronic Fund Transfer Act (EFTA) and its Official Staff Commentary (OSC). The proposal contains new protections for consumers who send remittance transfers to consumers or entities in a foreign country, by providing consumers with disclosures and error resolution rights. The proposed amendments implement statutory requirements set forth in the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). A copy of this lengthy proposed rule can be found here: http://www.gpo.gov/fdsys/pkg/FR-2011-05-23/pdf/2011-12019.pdf. - 11-CC-20 FRB - Ability to Repay Mortgage Loans (Due: 7/22/11)
The Federal Reserve Board (FRB) proposes a rule to amend Regulation Z (Truth in Lending) and its Official Staff Commentary (OSC) to implement amendments to the Truth in Lending Act (TILA) made by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act or Act). Regulation Z currently prohibits a creditor from making a higher-priced mortgage loan without regard to the consumer’s ability to repay the loan. The proposal would do the following: Implement the Dodd-Frank Act changes that expand the scope of the ability-to-repay requirement to cover any consumer credit transaction secured by a dwelling (excluding an open-end credit plan, timeshare plan, reverse mortgage, or temporary loan); Establish standards for complying with the ability-to-repay requirement, including by making a “qualified mortgage”; Implements the Dodd-Frank Act’s limits on prepayment penalties; and Would require creditors to retain evidence of compliance with this rule for 3 years after a loan is consummated. General rulemaking authority for TILA is scheduled to transfer to the Consumer Financial Protection Bureau (CFPB) on July 21, 2011. Accordingly, this rulemaking will become a proposal of the CFPB and will not be finalized by the Board. - 11-CC-19 CFPB - Identification of Enforceable Rules and Orders (Due: 6/30/11)
The Dodd-Frank Act requires the Bureau of Consumer Financial Protection (“CFPB” or “Bureau”) to publish in the Federal Register a list of the rules and orders that will be enforced by the CFPB. This notice sets forth a list for public comment. A final list will be published not later than the designated transfer date, July 21, 2011. Six NCUA rules have been proposed to be enforced by the CFPB (Parts 701.21, 707, 716, 717, 741 and 761). - 11-CC-18 NCUA - Voluntary Stabilization Prepayment Program (Due: 6/20/11)
In response to credit union industry urging, the NCUA Board has proposed to create a voluntary prepaid assessment program (Program) in an effort to improve the liquidity of the Corporate Stabilization Fund and provide enhanced flexibility in setting future Stabilization Fund assessments. Key elements of the Program are as follows: Participation would be purely voluntary and open to all federally insured credit unions able to meet the minimum participation amount of $10,000. NOTE: NCUA has excluded credit unions with less than $2.8 million in assets from this voluntary program; Liquidity would be provided to the Stabilization Fund by augmenting the 2011 and 2012 assessments from participating credit unions;NCUA would implement the voluntary prepaid assessment program only if a minimum aggregate amount (at least $300 million) could be raised, which would reduce mandatory assessments for all federally insured credit unions in 2011 and 2012; Beginning in 2013, NCUA would offset each participating credit union’s future Stabilization Fund assessments with any contributions they made to the voluntary program;The interest rate would be zero. Participating credit unions would not receive any interest or any other form of compensation from NCUA in connection with the program;A list of participating credit unions will not be published. A program outline regarding this proposal is available at http://go.usa.gov/jVy. - 11-CC-17 FRB - Escrow Accounts (Due: 5/2/11)
The Federal Reserve Board (FRB) has issued a proposed rule that would amend Regulation Z (Truth in Lending) to implement certain amendments to the Truth in Lending Act (TILA) made by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd Frank Act). Regulation Z currently requires creditors to establish escrow accounts for higher-priced mortgage loans secured by a first lien on a dwelling. The proposal would do the following: Lengthen the time for which a mandatory escrow account established for a higher-priced mortgage loan must be maintained [5 years]; Implement the Dodd Frank Act’s disclosure requirements regarding escrow accounts; and Exempt certain loans from the statute’s escrow requirement. The primary exemption would apply to mortgage loans extended by creditors that operate predominantly in rural or underserved areas, originate a limited number of mortgage loans, and do not maintain escrow accounts for any mortgage loans they service. - 11-CC-16 NCUA - Incentive-Based Compensation (Due: 5/31/11)
NCUA, along with the other federal financial institution regulators (the Agencies), has proposed rules to implement Section 956 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The proposed rule would require the reporting of incentive-based compensation arrangements by a “covered financial institution” (CFI) [defined as a financial institution with over $1 billion in assets], and prohibit incentive-based compensation arrangements at a CFI that provide excessive compensation or that could expose the institution to inappropriate risks that could lead to material financial loss. - 11-CC-15 NCUA - Net Worth and Equity Ratio (Due: 5/23/11)
On January 4, 2011, Senate Bill 4036 (the Bill) was signed into law, which, among other things, amends the statutory definitions of “net worth” and “equity ratio” in the Federal Credit Union Act (FCU Act). NCUA proposes to make conforming amendments to the definition of “net worth” as it appears in NCUA’s Prompt Corrective Action regulation and the definition of “equity ratio” as it appears in NCUA’s Requirements for Insurance regulation. NCUA also proposes to make technical changes in other regulations to ensure clarity and consistency in the use of the term “net worth,” as it is applied to federally-insured credit unions (FICUs). - 11-CC-14 NCUA - Interest Rate Risk (Due: 5/23/11)
NCUA proposes to amend its regulations to require federally insured credit unions (FICUs) to have a written policy addressing interest rate risk (IRR) management and an effective IRR program as part of their asset liability management. NCUA also is proposing draft guidance in the form of an appendix to its regulations to assist credit unions in meeting the proposed regulatory requirement. - 11-CC-13 FRB – Regulation CC Expedited Funds Availability (Due: 6/3/11)
This proposal will update Reg CC and related Official Staff Commentary in order to facilitate the ongoing transition to fully-electronic interbank check collection and return, to adjust funds availability schedules and model disclosure forms, and to increase from $100 to $200 the minimum amount of funds to be available next business day for funds received by check deposit. Some provisions mandated by Dodd-Frank Act. - 11-CC-12 FRB – Credit Scores in Adverse Action Notices (Due: 4/14/11)
This Comment Call contains a summary of the Federal Reserve Board’s proposal to amend the model adverse action notices in Regulation B and the Fair Credit Reporting Act to include the disclosure of credit scores and information relating to credit scores if a credit score is used in taking adverse action. These proposed amendments reflect the new content requirements in the FCRA that were added by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). - 11-CC-11 FRB and FTC – Credit Scores in Risk-Based Pricing Disclosures (Due:4/14/11)
This Comment Call contains proposed rules by the Federal Reserve Board (FRB) and Federal Trade Commission (FTC) to amend their respective risk-based pricing rules to require disclosure of credit scores and information relating to credit scores in risk-based pricing notices (RBPNs) if a credit score of the consumer is used in setting the material terms of credit. These proposed amendments reflect the new requirements in section 615(h) of the FCRA that were added by section 1100F of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). - 11-CC-10 Various Agencies –Garnishment of Federal Benefit Payments (Due:5/24/11)
The Department of the Treasury, Fiscal Service (Treasury); Social Security Administration (SSA); Department of Veterans Affairs (VA); Railroad Retirement Board (RRB); Office of Personnel Management (OPM) have issued an interim final rule to establish procedures financial institutions must follow when they receive a garnishment order against an account holder who receives certain types of Federal benefit payments by direct deposit. The rule requires financial institutions that receive such a garnishment order to determine the sum of such Federal benefit payments deposited to the account during a two month period, and to ensure that the account holder has access to an amount equal to that sum or to the current balance of the account, whichever is lower. - 11-CC-09 NCUA - References to Credit Ratings in NCUA Regulations (Due:5/2/11)
This Comment Call contains a summary of NCUA’s proposed rules to implement certain statutory provisions in Title IX of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act). The proposed rules replace or remove references to credit ratings in NCUA regulations. - 11-CC-08 IRS - Interest Reporting re Nonresident Alien Individuals (Due:4/7/11)
This Comment Call contains proposed IRS regulations that provide guidance on the reporting requirements for interest on deposits maintained at U.S. offices of certain financial institutions and paid to nonresident alien individuals. These proposed regulations affect persons making payments of interest with respect to such deposits. This document also provides a notice of public hearing on these proposed regulations and withdraws the notice of proposed rulemaking published on August 2, 2002 (67 FR 50386). - 11-CC-07 NCUA - Low Income Designation - Member Income Sampling (Due: 2/22/11)
In an effort to improve the opportunity to become a low-income designated credit union, NCUA is proposing to permit federal credit unions (FCUs) that do not qualify for a low-income designation using the geo-coding software the NCUA has developed for that purpose, to submit an analysis of a statistically valid sample of their member income data as evidence they qualify. The current rule requires, as an alternative to NCUA’s geo-coding software, that member data drawn from loan applications or member surveys be used to show a majority of the members are low-income. - 11-CC-06 NCUA - Share Insurance Advertising (Due: 2/28/11)
The NCUA Board proposes to revise certain provisions of NCUA’s official advertising statement rule. Specifically, insured credit unions will be required to include the statement in all radio and television advertisements, annual reports, and statements of condition required to be published by law. The NCUA Board also proposes to define the term ‘‘advertisement’’ and clarify size requirements for the official advertising statement in print materials. - 11-CC-05 NCUA - Share Insurance & Appendix (Due: 2/22/11)
Section 343 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) provides that, on a temporary basis, the NCUA Board shall fully insure the net amount ($250,000) that any member or depositor at an insured credit union maintains in a noninterest-bearing transaction account. Although this insurance coverage is self-implementing, and therefore already in place, this proposed rule would, among other things, provide that this insurance coverage is separate from, and in addition to, other coverage provided in NCUA’s share insurance rules, and would impose new disclosure requirements. - 11-CC-04 FRB - Regulation Z Threshold (Due: 2/1/11)
The Federal Reserve Board (FRB) proposes to increase the threshold for exempt consumer credit transactions under Regulation Z from $25,000 to $50,000, pursuant to the Dodd-Frank Act amendments to the Truth in Lending Act. This threshold would, on or after December 31, 2011, be adjusted annually by any annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers. - 11-CC-03 FRB - Interchange Fees (Due: 2/22/11)
This link will take you to CUNA’s CapWiz page. The major issues to comment on are rate setting factors Treasury needs to consider and ensuring the fairness of a two tier card network for small issuers. - 11-CC-02 FRB - Regulation Z MDIA (Due: 2/28/11)
The Federal Reserve Board (FRB) is publishing for comment an interim rule amending Regulation Z and its Official Staff Commentary (OSC), which revises its interim rule published on September 24, 2010. The first interim rule implemented certain requirements of the Mortgage Disclosure Improvement Act of 2008 and required creditors who extend consumer credit secured by real property or a dwelling to disclose summary information about interest rates and payment changes in a tabular format. This interim rule is effective January 30, 2011. Compliance with its provisions is optional, however, for transactions for which an application for credit is received by the creditor before October 1, 2011. Comments on this interim rule must be received on or before February 28, 2011. - 11-CC-01 Dept. of Justice - ADA Web Accessibility (Due: 1/ 24/11)
In this Advanced Notice of Proposed Rulemaking, the Department of Justice is considering revising the regulations implementing title III of the Americans with Disabilities Act (ADA or Act) in order to establish requirements for making the goods, services, facilities, privileges, accommodations, or advantages offered by public accommodations via the Internet, specifically at sites on the World Wide Web (Web), accessible to individuals with disabilities. The definition of a “public accommodation” in Title III of the ADA includes “(F) a bank…or other service establishment,” which would include credit unions.
Comment Calls - 2010
Comment Calls - 2009
- 09-CC-22, Mortgage Loan Transfers, Due: 1/19/10
- 09-CC-21 Reg Z HELOC Disclosures Due:12/24/09 *Proposal rescinded by FRB 2/1/11-Deferred to CFPB
- 09-CC-20, Bank Secrecy Act - Due: 12/16/09
- 09-CC-19, Regulation E – Gift Cards, Due: 12/21/09
- 09-CC-18 Regulation Z Proposal-Credit Card Act Due: 11/20/09
- 09-CC-16 , Regulation Z Interim Final Rule-Credit Act 97-2003, Due: September 21, 2009
- 09-CC-15, Proposed Interagency Guidance—Funding and Liquidity Risk Management, Due September 4, 2009
- 09-CC-14, Exception to the Maturity Limit on Second Mortgages, Due: August 24, 2009
- 09-CC-13, Mortgage Acts and Practices, Due: July 30, 2009
- 09-CC-12, Registration of Mortgage Loan Originators, Due: July 9, 2009
- 09-CC-11, Regulation Z – Private Education Loans, Due: May 19, 2009
- 09-CC-10, NCUA Part 707 – Truth in Savings, Due: May 19, 2009
- 09-CC-09, NCUA – Reporting and Record Retention, Due: May 19, 2009
- 09-CC-08, Not Yet Issued
- 09-CC-07, Recognition/Presentation of Other-Than-Temporary Impairments (OTTI), Due: March 25, 2009
- 09-CC-06, FASB Statement No. 157 – Fair Value Measurements, Due: March 25, 2009
- 09-CC-05, Federal Credit Union Operating Fee, Due: April 30, 2009
- 09-CC-04, Corporate Credit Unions, Due March 30, 2009
- 09-CC-03, Regulation E Proposal - Overdraft Services, Due: February 25,2009
- 09-CC-02, Regulation Z Proposal - Mortgage Loan Disclosures, Due February 4, 2009
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Comment Calls - 2008
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Comment Calls - 2007
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Comment Calls - 2006
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Regulatory Affairs
