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CFPB rulemaking actions regarding overdraft, payday lending and TRID implementation were discussed by NAFCU with the bureau yesterday during a meeting with Acting Deputy Director David Silberman.

NAFCU President and CEO Dan Berger, along with Executive Vice President of Government Affairs and General Counsel Carrie Hunt, Director of Regulatory Affairs Alicia Nealon and Regulatory Affairs Counsel Alexander Monterrubio, attended yesterday's meeting at the bureau's headquarters.

Overdraft
NAFCU has requested that the bureau, in any rulemaking actions, not curtail credit unions' programs. Last week, CFPB urged the nation's 25 largest retail banks to offer lower-risk deposit accounts to "help consumers avoid overdrafting." NAFCU has noted that credit unions already offer those types of accounts to their members.

Payday lending
A proposed rule on payday lending is expected sometime in the first quarter, according to the bureau's fall rulemaking agenda. NAFCU has strongly urged the bureau to craft any future rulemaking to ensure credit unions are not forced to withdraw from providing a viable alternative to predatory payday lenders.

TILA-RESPA integrated mortgage disclosure (TRID) rules
NAFCU has repeatedly asked the bureau to consider credit unions' good-faith efforts toward compliance. Last month, CFPB published a new fact sheet on how construction loans are affected by TRID.

CFPB guidance
NAFCU has called on the bureau to provide more written guidance regarding implementation of its rules and regulations. CFPB offers a help line for financial institutions seeking input from the bureau. NAFCU has heard reports of conflicting guidance as a result and continues to urge CFPB to establish procedures for much-needed official written legal advisory opinions for clearer guidance.