February 22, 2019

NAFCU, regulators' efforts updated in S. 2155 guide

S.2155 guideSee how NAFCU and regulators are working to address credit unions' concerns and implement provisions of the Economic Growth, Regulatory Relief, and Consumer Protection Act (S. 2155) in an updated summary guide. NAFCU's highly used and downloaded guide details credit union-related provisions within the law, including their effective dates and other specifics.

This guide has been updated to reflect:

  • The NCUA's proposed rule to increase the threshold for commercial real estate-related financial transactions to be exempt from formal appraisal requirements from $250,000 to $1 million. This is an attempt to make the commercial real estate appraisal standards for credit unions more consistent with the changes other regulators have made for banks; banks' regulators have issued a proposal to reform residential real estate proposals as well.
  • NAFCU's efforts to obtain more guidance related to elder financial abuse provisions of S. 2155. NAFCU met with the NCUA on the issue in December, and previously with the CFPB's Office of Older Americans.
  • The Department of Veterans Affairs (VA) interim final rule, which went into effect Feb. 15, amending its regulations regarding VA-guaranteed or insured cash-out refinance loans.
  • The Federal Housing Finance Agency's proposed rule to establish a process for evaluating new credit scoring models for use by the government-sponsored enterprises (GSEs). The FHFA abandoned a previous initiative to evaluate potential changes to the GSEs' credit score requirements to instead focus on the S. 2155 provision. Comments on the proposed rule are due to the FHFA March 21.

The 12-page table is available for download. NAFCU has also detailed the implications S. 2155 will have on credit unions in various posts on its NAFCU Compliance Blog.

NAFCU continues to work with policymakers on clarifications regarding S. 2155 compliance.