MCUL Comments on CFPBs Request to Promote Student Loan Affordability 

Based on a request for comment from the CFPB on the Initiative to Promote Student Loan Affordability, MCUL responded on April 8 describing the credit union difference and special ability credit unions have to assist members with affordable student loan options when they have exhausted federal student loan options. The MCUL pointed out that private student loan delinquency nationwide is 5.4%, but only 1.46% for credit unions. In part, this is due to the fact that private student loans are underwritten by credit and other risk criteria prior to being funded, similar to other credit union loans. MCUL strongly discouraged the CFPB from implementing a regulation or guidance that would require the financial services industry to comply with private student loan modification requirements, stating because credit unions’ private student loan modification plans are based on a member service model and are unique and specific to individual situations and any such regulation would be restrictive and burdensome.


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