NAFCU opposes the CFPB’s examination and enforcement authority over credit unions, given they were not responsible for the financial crisis and are more highly regulated than any other financial depository institution. NAFCU also strongly supports legislative improvements to change the structure of the CFPB from an unaccountable, single director, who is removable only for cause, to a bipartisan commission.
History has shown that a robust and thriving credit union industry is good for our nation’s economy, as credit unions fill a void for consumers and small businesses in the marketplace that may otherwise not be met by other institutions. The CFPB should use its statutory exemption authority to exclude credit unions from rulemakings to reduce the regulatory burden that has crippled many institutions so that credit unions may continue to provide value to our nation's economy. Since its inception, the CFPB has finalized a number of regulations that have significantly impacted the credit union industry. Although NAFCU has a number of concerns with all of the CFPB’s rules, this letter