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The second half of March was dominated by conversations around the recent failures of Silicon Valley Bank and Signature Bank. As NAFCU President and CEO Dan Berger noted on Bloomberg TV, credit union deposits remain safe and over 90 percent of deposits are insured. 

Additionally, Mike Wilson, chief experience officer at Members 1st Credit Union (Enola, PA.), testified on NAFCU’s behalf at the House Small Business Committee’s hearing on the CFPB’s Section 1071 proposed rule.

Watch NAFCU’s latest video as NAFCU Senior Vice President of Government Affairs Greg Mesack provides additional updates from March. Be sure to join NAFCU’s efforts to tout the credit union difference to policymakers and the public via #NAFCUNation.

Prominent Hearings 

·       On March 28, NAFCU-member Michael Wilson, Chief Experience Officer of Members 1^st FCU, testified before the House Small Business Subcommittee on Economic Growth, Tax, and Capital Access for a hearing on the CFPB’s Section 1071 Small Business Lending Data Collection proposed rule. In his statement, Wilson highlighted the costs and other burdens this proposal would have on credit unions and offered NAFCU’s recommendations for reducing those burdens. 

·       The Senate Banking Committee and House Financial Services Committee (HFSC) each held a hearing on the recent bank failures. NAFCU wrote to the committees to reaffirm the financial strength of the credit union system and advocate for parity between NCUA and FDIC deposit insurance coverage levels. 

·       The House and Senate Small Business Committees held SBA oversight hearings. NAFCU’s letters made the case for a fair regulatory framework for fintech lenders and cautioned against SBA proposals that would loosen underwriting standards for SBA-guaranteed loans while also allowing underregulated fintechs to participate in SBA lending programs. 

·       The HFSC Subcommittee on Financial Institutions and Monetary Policy held a hearing on potential CFPB reform. NAFCU’s letter discussed a series of key credit union issues, including the Section 1071 and 1033 rulemakings, the proposed rule on credit card late fees, examination efficiency, Regulation E, and our longstanding request for the Bureau to use its statutory small entity exemption authority to provide credit unions blanket relief from onerous requirements. 

·       For the HFSC's and Senate Banking Committee’s Federal Reserve Hearings, NAFCU wrote to oppose the creation of a central bank digital currency, support disclosure of entities with access to Federal Reserve Bank accounts and services, and request an extended timeline for compliance with the Fed’s rule on debit card network requirements. 

Key Legislation 

·       Rep. French Hill (R-AR) introduced H.R. 1806, the Small LENDER Act, with cosponsors Rep. Roger Williams (R-TX), the chairman of the House Small Business Committee, and Rep. Blaine Luetkemeyer (R-MO). This NAFCU-backed legislation would modify elements of the CFPB’s Section 1071 proposed rule to exempt small financial institutions and provide a longer compliance timeline. NAFCU wrote to Rep. Hill to thank him for his leadership on this issue. 

·       Sens. Kyrsten Sinema (I-AZ), Bill Hagerty (R-TN), Alex Padilla (D-CA), and Thom Tillis (R-NC) introduced the Senate version of the Credit Union Board Modernization Act, S. 610. NAFCU wrote in support of this legislation that would reduce the required number of annual board meetings to six from the current requirement of 12 for credit unions in good financial condition. A companion bill has already passed the House. 

·       Three important pieces of legislation concerning the structure and function of the CFPB were introduced in March: the Transparency in CFPB Cost-Benefit Analysis Act (H.R. 1313), the Consumer Financial Protection Commission Act (H.R. 1410), and the Making the CFPB Accountable to Small Businesses Act (H.R. 1749). NAFCU President and CEO Dan Berger provided a statement in support of the last of these, hailing the legislation’s requirement that the CFPB tailor regulations through the use of SBREFA review panels and thanking its sponsor, Rep. Scott Fitzgerald (R-WI). 

Meetings 

·       NAFCU President and CEO Dan Berger met with NCUA Chairman Todd Harper to discuss credit union involvement with the Greenhouse Gas Reduction Fund.  

·       The Federal Open Market Committee (FOMC) concluded its March meeting March 22, where the committee raised rates 25 basis points to a range of 4.75 to 5 percent – the ninth consecutive meeting ending with a hike. NAFCU Economists Curt Long and Noah Yosif discuss the FOMC and other economic issues in their new Quarterly Video Update.  

·       The NCUA Board met March 16 and finalized the subordinated debt rule, granting two previous NAFCU requests related to the Emergency Capital Investment Program (ECIP) and maximum maturity limits. 

Regulatory Alerts/Rulemakings 

·       March 24: NAFCU published a Regulatory Alert analyzing the CFPB’s request for information on data brokers and other entities that collect and sell consumer information. 

·       March 29: The CFPB finally published its proposed rule on credit card late fees in the Federal Register. Member credit unions can submit comments through NAFCU’s Regulatory Alert; comments are due to the Bureau May 3. 

·       March 30: The CFPB finalized its rule to implement section 1071 of the Dodd-Frank Act, related to small business lending data collection.  

Comment Letters 

·       March 29: NAFCU wrote to the CFPB in support of an ICBA trial disclosure application meant to increase the availability of affordable single-close construction-to-permanent loans.  

·       March 23: NAFCU wrote to the FHFA requesting reinstatement of the seasoned bulk transaction window. 

·       March 17: NAFCU submitted comments to FinCEN on the report that will be used to collect beneficial ownership information.  

·       March 15: NAFCU wrote to NCUA Chairman Todd Harper defending credit unions’ compliance with the Electronic Fund Transfer Act and Regulation E in response to a letter from Senators Reed (D-RI), Menendez (D-NJ), Warren (D-MA), Brown (D-OH), and Warner (D-VA) that incorrectly claimed credit unions and other depository institutions are neglecting their responsibility to address fraud in the Zelle network. 

·       NAFCU signed on to two joint letters in March, one to the CFPB requesting that the Bureau release the data and analysis underlying its proposed rule on credit card late fees and one to the FCC making recommendations to improve the redress process for incorrectly blocked messages.