Compliance Blog

Aug 16, 2017
Categories: Accounts

We Need You! NAFCU's Annual Federal Reserve Survey

We need your help! Yes, you!  Please make your voice heard by completing NAFCU's Annual Federal Reserve Survey.

What is it?

Since 1992, NAFCU's Board of Directors has met yearly with the members of the Board of Governors of the Federal Reserve System to discuss issues of mutual interest and concern affecting credit unions.  For example, among other things, NAFCU provides information to the Fed on credit union financial conditions, credit union service to members and use of Fed services, key legislative and regulatory issues facing credit unions, and other critical topics of importance for that particular year. 

In preparation for the annual meeting NAFCU produces a written report for each yearly session detailing the latest issues and trends affecting credit unions and the impact of Fed actions. NAFCU's Annual Federal Reserve Survey is an annual assessment of NAFCU members covering the topics discussed in the annual NAFCU Report on Credit Unions.  NAFCU's 2016 Report on Credit Unions was referenced by the Treasury Department in their recent study, which contained a number of credit union-specific and NAFCU-backed recommendations aimed at fostering credit union service to members and communities.

Annual Report

The 2016 NAFCU Report on Credit Unions highlighted a number of areas of concern for credit union compliance officers.  For example, our 2016 report emphasized that credit unions are significantly hindered by regulatory burden and growing compliance costs:

"91.1% of respondents to NAFCU’s 2016 Federal Reserve Meeting Survey cited 'total compliance activities' as an area in which significant expense increases are necessary for the near-term. While smaller credit unions continue to disappear due to the growing burden, all credit unions are finding the current regulatory environment challenging. Credit unions did not contribute to the financial crisis yet are still subject to increasing regulatory requirements mandated under the Dodd-Frank Act."

Our 2016 report also highlighted our members' concerns with respect to the following regulatory and compliance issues:

Federal Reserve

  • Payments
  • Debit Card Interchange Fees
  • Regulation D
  • Regulation CC

Consumer Financial Protection Bureau

  • Unfair, Deceptive, or Abusive Acts and Practices
  • Debt Collection
  • Qualified Mortgages
  • Mortgage Servicing
  • Reputation Risk
  • Remittances
  • Home Mortgage Disclosure Act Requirements
  • Privacy
  • Overdraft
  • Payday Lending
  • Arbitration

National Credit Union Administration

  • Risk-Based Capital
  • Investment Authority

Department of Defense

  • Military Lending Act

Federal Communications Commission

  • Telephone Consumer Protection Act

By drawing attention to these crucial issues, our hope is that the Fed, and other federal financial regulators, can gain a better appreciation for our members' concerns with respect to regulatory burden and the tremendous compliance and operational challenges associated with implementing many extensive and complex rules.

Why does it matter?

NAFCU’s annual meeting with the Federal Reserve is one of the more important ways we ensure that our members’ concerns are heard at the highest levels of government.

Credit unions have always been some of the most highly regulated of all financial institutions, facing restrictions on who they can serve and their ability to raise capital. Additionally, there are many consumer protections built into the Federal Credit Union Act, such as the only federal usury ceiling on financial institutions, the statutory prohibition on prepayment penalties, and the arbitrary cap on credit union member business lending.  Despite the fact that credit unions are already heavily regulated and did not cause the financial crisis, they are still laboring under the weighty regulatory burden in the post-Dodd-Frank environment. Small credit unions, in particular, struggle to afford costly compliance expenses. Those that cannot keep up with ballooning compliance costs have disappeared due to merger at an alarming rate—the industry continues to lose roughly one credit union per day.

Now, more than ever, credit unions' voices must be heard.

Participate in NAFCU's 2017 Annual Federal Reserve Survey

In preparation for NAFCU’s 2017 meeting with the Federal Reserve, we would like your credit union's feedback on a variety of topics, including lending, liquidity and housing conditions, as well as a number of regulatory issues and strategic challenges. Your responses to these survey questions are very important to both the Federal Reserve Board and to credit union advocacy efforts.  Every survey response is helpful and greatly appreciated! Please participate today, or pass the survey along to the appropriate personnel within your credit union.

The survey results will be summarized the 2017 Report on Credit Unions. Participants will receive a free copy of the 2017 report later this year.

The deadline for the survey is August 25, 2017. Participants can either complete the survey online or download a fillable pdf version.

We look forward to hearing your thoughts!