MCUL Issues Comment Letters to CFPB and NCUA on Recent Proposals 

On Oct. 8, MCUL issued a pair of comment letters to the NCUA in response to its proposals on emergency liquidity and on allowing NCUA to declare a credit union to be in “troubled condition.” MCUL opposed both proposals.

The three-tiered system proposed for liquidity is not necessary or justified, as enough guidance exists for credit unions currently on emergency liquidity measures. Further, specifying only two avenues for large credit unions to demonstrate access to emergency liquidity measures is limiting, where more flexibility would be beneficial. The proposal also asked for comments on applying the complex Basel III proposed banking standards to credit unions, a move MCUL opposes, especially until the full impact of those standards can be studied. 

On Oct. 9, MCUL issued its response to the CFPB on its comprehensive mortgage servicing proposals affecting both Regulation X and Z.  MCUL will be finalizing comments on CFPB proposals dealing with appraisals and valuations under Regulation B and higher-risk mortgage appraisals under Regulation Z for submission on Oct. 15, as well as comments on the CFPB’s mortgage loan originator proposal, due on Oct. 16. 

“Continuously and aggressively advocating on behalf of credit unions with our federal regulatory agencies such as NCUA and CFPB, and doing everything we can to mitigate the ever-growing compliance burden for our members, is an extremely high priority for the MCUL,” CEO David Adams said. “As part of that process, input from Michigan credit unions as to their concerns with current regulatory proposals is critical, and I encourage all credit unions to reach out to our Governmental Affairs team and share their views and needs.” 

Details on federal regulatory proposals, and MCUL’s comment calls and comment letters can be found by clicking here.


Submissions to Monitor may be emailed. Bryan Laviolette is the editor of Monitor. Contact him by email or call (800) 262-6285, ext. 233. The newsletter of the Michigan Credit Union League is published Monday mornings or Tuesday mornings when Monday is a holiday. There is no Monitor the week after Christmas and the week after the Annual Convention and Exposition. The MCUL reserves the right to edit submissions for clarity and space.
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