Last week, CUNA presented to the U.S. House Financial Services Committee on a myriad of potential areas for regulatory relief proposals, ranging from the CFPB rules and the Dodd-Frank Act to the Federal Credit Union Act and NCUA rules that need revision.
Included in this testimony were several items strongly recommended by MCUL CEO David Adams to CUNA, and based on Michigan credit union feedback. These included a need to revisit and raise the exemption threshold for the rule on international remittance transfers, and a need for more flexibility in the 120-day prohibition on filing or noticing with regard to foreclosures, under the new CFPB mortgage servicing rules. Many credit unions currently providing international remittance transfers as a service for members will be forced to discontinue the practice, even under proposed amendments designed to improve the functionality of the rule. And the 120-day prohibition in the mortgage servicing rule fails to provide any relief if the borrower is not participatory, unlike one positive feature of Michigan’s state 90-day pre-foreclosure workout law which covers similar matters.
The MCUL also continues to review credit unions’ federal governing laws and regulations, including Dodd-Frank and related CFPB rules, the Federal Credit Union Act, and NCUA’s surrounding regulations and bylaws, to identify additional opportunities to recommend critical changes for Michigan’s credit unions to both CUNA and our regulators and congressional delegation. MCUL welcomes and encourages input from its member credit unions in this process.