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NAFCU President and CEO Dan Berger today is engaging with the NCUA, CFPB, Federal Housing Finance Agency (FHFA) and Treasury Department on the association's 2018 advocacy priorities and the role each regulator can play in helping NAFCU work toward creating a regulatory environment in which credit unions can thrive.

Berger detailed those priorities in letters today to each agency. As released last week, NAFCU's 2018 advocacy priorities include:

• creating a regulatory environment that allows credit unions to grow by addressing issues such as housing finance reform, field of membership, risk-based capital reform and continuing to defend the credit union tax exemption;
• reducing the regulatory burden and creating appropriate, tailored regulations for credit unions by increasing the CFPB's use of its exemption authority and addressing issues such as member business lending and the unfair, deceptive, or abusive acts and practices (UDAAP);
• ensuring a fair playing field for all similarly situated depositories by repealing the Durbin Amendment, passing national data security legislation and regulating fintechs;
• increasing government transparency and accountability by reforming the CFPB's structure to a bipartisan commission and returning stabilization assessment monies to credit unions; and
• maintaining the NCUA's independence by exempting credit unions from CFPB authority and keeping the agency out of the congressional appropriations process.

In his letter to the NCUA, Berger specifically asks the agency to: reexamine capital planning and stress testing requirements, issue guidance on asset securitization, amend the current federal credit union interest rate cap and reform federal credit union bylaws.

To the CFPB, Berger requests that the bureau: review all regulations, increase use of its exemption authority for credit unions under the Dodd-Frank Act, revise the definition of qualified mortgage, review the reputation risk associated with its Consumer Complaint Database, revisit its Home Mortgage Disclosure Act requirements and pull back efforts to alter overdraft programs.

In his letter to the FHFA, Berger strongly urges the agency to: work on the Common Securitization Platform and Single Security, experiment with or expand various credit risk transfer transactions and move forward with alternative credit-scoring models.