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February 10, 2012

Fed-proposed rules could get CFPB action

Feb. 10, 2012 – Credit unions will want to monitor several proposed rules, including one addressing credit insurance disclosures, the Federal Reserve Board transferred to the Consumer Financial Protection Bureau recently.

The Dodd-Frank Act transferred to the CFPB all consumer financial services rules issued previously by more than a half-dozen federal financial institution regulators. Those include final as well as proposed rules, and the CFPB can decide to finalize the proposals as they were first released or issue revised proposals. The bureau did a combination of the two recently, both finalizing the Fed's proposed remittances rule to meet a statutory deadline for action and issuing a new proposed rule.

The NAFCU Compliance Blog carried a post on this Thursday that addresses the CFPB's general authority and several Fed proposals yet to receive final action. Among these are the Fed's Regulation Z proposals addressing borrowers' ability to repay mortgages; escrow accounts; closed-end mortgages; and credit insurance, right of rescission and home equity lines of credit.

The Fed announced last February that it wouldn't complete the last batch of proposals noted above. And the proposal on credit insurance poses a special concern given the negative bias evident in the Fed's proposed model disclosures. "If your credit union offers these products, this is definitely an area to keep an eye on," notes Steve Van Beek, NAFCU's director of regulatory compliance.

Thursday's blog entry includes links to those Fed proposals as well as NAFCU's Regulatory Alert released this week on remittances. Any credit union can access the NAFCU Compliance Blog.