2018 NAFCU Comment Letters
Browse 2018 regulatory comment letters sent to agencies on behalf of NAFCU member credit unions.
CFPB
June 7, 2018 - Rulemaking Processes RFI
June 4, 2018 - Public Reporting Practices of Consumer Complaint Information RFI
May 29, 2018 - External Engagements RFI
May 21, 2018 - Supervision Program RFI
May 14, 2018 - Enforcement Processes RFI
May 7, 2018 - Rules of Practice for Adjudication Proceedings RFI
April 26, 2018 - Civil Investigative Demands RFI
February 12, 2018 - Consumers' Experience with Free Access to Credit Scores
February 9, 2018 - Joint Trades on 2016 Amendments to Mortgage Servicing Rule
January 17, 2018 - Collection of HMDA Data Points
January 16, 2018 - Overdraft Disclosure Forms
January 9, 2018 - NAFCU's 2018 Priorities
DOD
January 31, 2018 - Amending the MLA Interpretive Rule
FCC
June 7, 2018 - Reassigned Numbers Database
March 22, 2018 - Decision in Telephone Consumer Protection Act Lawsuit
January 23, 2018 - Advanced Methods to Target and Eliminate Unlawful Robocalls
Federal Reserve System
May 14, 2018 - Joint Trades on Proposed Amendments to Regulation J
March 2, 2018 - Borrower-in-Custody Requirements for Electronically-Signed Loans
FHFA
June 4, 2018 - Regulatory Review
April 19, 2018 - Affordable Housing Program Amendments
March 29, 2018 - Credit Score Request for Input
January 26, 2018 - Joint Trades on Credit Score RFI
January 9, 2018 - NAFCU's 2018 Priorities
FTC
February 1, 2018 - Unfair and Deceptive ADA Lawsuits
IRS
April 24, 2018 - Response to Senator Hatch Calling for Increased Oversight of Credit Unions
January 16, 2018 - Nonqualified Deferred Compensation Plans
NCUA
May 31, 2018 - Federal Credit Union Loan Interest Rate Ceiling
May 21, 2018 - Proposed Suspension and Debarment Procedures
May 21, 2018 - Federal Credit Union Bylaws ANPR
April 2, 2018 - Modernizing Data Collection for Supervision of Credit Unions
April 2, 2018 - Involuntary Liquidation and Claims Procedures
March 28, 2018 - Extended Exam Cycle for Credit Unions Above $1 Billion in Assets
February 21, 2018 - Asset Securitization
January 31, 2018 - Amending the MLA Interpretive Rule
January 9, 2018 - NAFCU's 2018 Priorities
January 3, 2018 - Electronic Loan, Deposit, and Investment Data Collection
NIST
January 19, 2018 - Version 1.1 of the Framework for Improving Critical Infrastructure Cybersecurity
Treasury
January 9, 2018 - NAFCU's 2018 Priorities
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Browse 2017 regulatory comment letters sent to agencies on behalf of NAFCU member credit unions.
CDFI Fund
March 10, 2017 - RFI on Certification Criteria
CFPB
December 14, 2017 - Debt Collection Information Collection
December 4, 2017 - HMDA Delay
November 27, 2017 - Acting Director Mulvaney
November 17, 2017 - Mortgage Servicing Rules
November 17, 2017 - Strategic Plan
November 15, 2017 - Mortgage Servicing Rules Under the Real Estate Settlement Procedures Act (Regulation X)
October 10, 2017 - Amendments to Federal Mortgage Disclosure Requirements under the Truth in Lending Act (Regulation Z)
September 15, 2017 - Equifax Data Breach
September 13, 2017 - Request for Information on Small Business Lending
August 14, 2017 - Amendments to Rules Concerning Prepaid Accounts
July 31, 2017 - Temporary Increase in Institutional and Transactional Coverage Thresholds for Open-End Lines of Credit
July 28, 2017 - Ability-to-Repay/Qualified Mortgage Rule Assessment
July 7, 2017 - 2013 RESPA Servicing Rule Assessment
June 7, 2017 - Consumer Credit Card Market
May 25, 2017 - Technical Corrections and Clarifying Amendments to HMDA Final Rule
May 23, 2017 - Joint Trades Small Business Lending Data Collection Comment Due Date Extension
May 22, 2017 - Remittance Rule Assessment
May 19, 2017 - Alternative Data
May 17, 2017 - HMDA Implementation Date Delay
May 9, 2017 - Credit Union Small Business Lending
May 3, 2017 - Amendments to ECOA (Regulation B) Ethnicity and Race Information Collection
April 5, 2017 - Proposed Prepaid Rule Effective Date Extension
February 21, 2017 - Consumer Access to Financial Records
January 6, 2017 - 2017 Priorities for Credit Unions
DOD
May 25, 2017 - Request for MLA Clarification and FAQ Language
March 22, 2017 - Extension of MLA Credit Card Compliance Deadline
DOJ
November 9, 2017 - ADA Website Accessibility
DOL
September 25, 2017 - Request for Information on Overtime Rule
August 4, 2017 - Fiduciary Rule and Prohibited Transaction Exemptions
July 21, 2017 - Fiduciary Rule and Prohibited Transaction Exemptions
May 22, 2017 - Fiduciary Duty Rule Delay
March 17, 2017 - Fiduciary Duty Rule Extension Proposal
FASB
June 5, 2017 - Suspend Implementation of Accounting Standard Update on Credit Losses
FCC
November 6, 2017 - Re: CUNA's TCPA Petition
August 28, 2017 - Reassigned Numbers and TCPA
March 10, 2017 - Joint Trades Letter Regarding "Prior Express Consent" under TCPA
March 9, 2017 - Re: Petition for Rulemaking and Declaratory Ruling (TCPA)
January 23, 2017 - Telephone Consumer Protection Act
Federal Reserve System
August 1, 2017 - Regulation CC – Availability of Funds and Collection of Checks
April 18, 2017 - Joint Trades Letter Regarding the Fed's Role in the Payments System
FHFA
October 27, 2017 - Strategic Plan for Fiscal Years 2018-2022
October 19, 2017 - NAFCU ICBA Joint Letter to Director Watt - GSE Capital Buffers
September 5, 2017 - 2018-2020 Enterprise Housing Goals
August 31, 2017 - Federal Home Loan Bank Capital Requirements
July 28, 2017 - Improving Language Access for LEP Borrowers
July 7, 2017 - Fannie Mae and Freddie Mac's Proposed Underserved Markets Plans
June 27, 2017 - Joint Trades Letter on Improving Language Access for LEP Borrowers
March 20, 2017 - Chattel Pilot RFI
FinCEN
April 3, 2017 - SAR Information Collection
FTC
September 15, 2017 - Equifax Data Breach
NCUA
December 28, 2017 - Capital Planning
December 4, 2017 - Proposed Advertising Rule
December 1, 2017 - Draft Strategic Plan 2018-2022
November 20, 2017 - Regulatory Reform Agenda
November 14, 2017 - Overhead Transfer Rate Methodology
November 9, 2017 - Home Mortgage Disclosure Act (HMDA) “good faith efforts”
November 1, 2017 - Recent Developments of Federal Banking Agencies
October 27, 2017 - 2018 & 2019 Proposed Budget
October 27, 2017 - Oral Remarks for 2018 & 2019 Proposed Budget
September 29, 2017 - Emergency Mergers
September 15, 2017 - Equifax Data Breach
September 5, 2017 - SIF Equity Distributions
August 31, 2017 - Corporate Credit Unions
August 28, 2017 - Temporary Corporate Credit Union Stabilization Fund Closure and Share Insurance Fund Normal Operating Level Increase
August 25, 2017 - Overhead Transfer Rate Methodology
August 11, 2017 - Regulatory Review
August 7, 2017 - Voluntary Mergers of Federally Insured Credit Unions
August 3, 2017 - Supervisory Review Committee; Procedures for Appealing Material Supervisory Determinations
August 3, 2017 - Appeals Procedure
August 2, 2017 - Asset Securitization
July 28, 2017 - Current Approval Process of Voluntary Credit Union Mergers
July 18, 2017 - Mid-Year Budget Review
May 9, 2017 - Puerto Rico Bankruptcy
May 8, 2017 - Alternative Capital ANPR
April 24, 2017 - NAFCU's Position on CFPB Reform and Pending Rules
January 23, 2017 - Revisions to the Freedom of Information Act Regulation
January 17, 2017 - Asset Securitization
January 13, 2017 - Federal Credit Union Loan Interest Rate Ceiling
January 9, 2017 - Share Insurance Fund Premium
January 6, 2017 - 2017 Priorities for Credit Unions
January 5, 2017 - Private Flood Insurance
OCC
January 13, 2017 - Special Purpose National Bank Charters for Fintech Companies
SBA
November 15, 2017 - Reducing Regulatory Burden RFI
The White House
July 6, 2017 - Re: Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure
Treasury
December 15, 2017 - IRS Tax Transcript Processing
November 9, 2017 - Financial Technology and Innovation
July 31, 2017 - Reducing Regulation and Controlling Regulatory Costs
July 3, 2017 - Credit Union Support of Recommendations in Report, "A Financial System that Creates Economic Opportunities"
May 16, 2017 - Credit Union Benefits to Main Street
April 24, 2017 - Recommendations from the Credit Union Roundtable (Mnuchin)
April 14, 2017 - Recommendations from the Credit Union Roundtable
February 28, 2017 - Proposed FSOC Review Priorities
January 30, 2017 - Federal Government Participation in the Automated Clearing House
VA
June 12, 2017 - Revisions to Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans
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Browse 2016 regulatory comment letters sent to agencies on behalf of NAFCU member credit unions.
CDFI
May 5, 2016 - Upcoming Community Development Advisory Board Meeting
CFPB
November 7, 2016- Payday Lending RFI
October 21, 2016 - Amendments Relating to Disclosure of Information and Records
October 18, 2016 - TRID Fix Proposal
October 7, 2016 - Payday Lending
September 29, 2016 - Consumer Response Company Response Survey
September 23, 2016 - Third-Party Debt Collection
August 19, 2016 - Arbitration Proposal
August 9, 2016 - Amendment to the Annual Privacy Notice Requirement
June 10, 2016 - Student Loan Payback Playbook
May 26, 2016 - Model Bankruptcy Periodic Statements
May 26, 2016 - Joint Letter on Model Bankruptcy Periodic Statements
April 25, 2016 - HELP Act Interim Final Rule (Operations in Rural Areas under TILA)
April 11, 2016 - Section 1022 Exemption Authority and PAL Loans
March 22, 2016 - HMDA Resubmission Guidelines
March 17, 2016 - Section 1022 Exemption Authority
March 4, 2016 - Overdraft Programs
February 18, 2016 - Generic Info Collection
January 11, 2016 - HMDA Information Collection
DOD
September 16, 2016 - Additional Guidance and Effective Date for MLA
May 31, 2016 - Extension of Exemption for Consumer Credit Cards from MLA
DOJ
August 8, 2016 - ADA Web Accessibility
FASB
April 1, 2016 - NAFCU Joint Committee Letter on CECL
February 11, 2016 - Issue Another CECL Exposure Draft
February 1, 2016 - Extend CECL Effective Date
FCC
June 6, 2016 - TCPA Proposal
May 2, 2016 - TCPA Clarification
Federal Reserve
March 20, 2016 - Interchange EGRPRA
FFIEC
July 5, 2016 - CC Rating System Proposal
January 13, 2016 - Agency Information Collection Activities for the FFIEC Cybersecurity Assessment Tool
FHFA
October 13, 2016 - Single-Family Credit Risk Transfer
September 6, 2016 - Single Security and Common Securitization Platform Update
March 22, 2016 - Principal Reduction
March 15, 2016 - Duty to Serve Proposal
January 11, 2016 - Proposed National Survey of Existing Mortgage Borrowers
FinCEN
January 8, 2016 - BSA CDD: Request for More Time to Comment
January 21, 2016 - Regulatory Impact Assessment & Initial Regulatory Flexibility Analysis
FLEC
May 10, 2016 -National Strategy Update
NCUA
December 8, 2016 - Chartering and Field of Membership Manual Changes
December 5, 2016 - Equity Fund Ratio and 2017 Projections
November 3, 2016 - 2017 & 2018 Budgets
October 27, 2016 - Written Testimony for NCUA's Public Budget Briefing
October 20, 2016 - Payment to U.S. Treasury and Refund to Credit Unions
October 5, 2016 - Usury Ceiling under the FCU Act
September 2, 2016 - Modernization of FOM Process and Procedures
August 26, 2016 - Modernization of Bylaws
August 19, 2016- Amendments to the Community Development Revolving Loan Fund
August 12, 2016 - RFI on Call Report Modernization
August 5, 2016 - Regulatory Review
August 2, 2016 - NCUSIF Equity Ratio
July 29, 2016 - Exam Flexibility
July 21, 2016 - Incentive-Based Compensation
July 15, 2016 - 2016 Mid Year Budget Review
July 11, 2016 - Credit Union Capital
July 8, 2016 - Request for Extended Time to Comment on Incentive Based Compensation Proposed Rule
June 24, 2016- FCU Occupancy, Planning, and Disposal of Acquired and Abandoned Premises
June 23, 2016- NAFCU Support of the Financial Services for the Underserved Act of 2016 (HR 5541)
June 10, 2016 - Information Collection on Secondary Capital
May 31, 2016 - Information Collection on Investment and Deposit Activities
May 23, 2016 - CLF Information Collection Request
April 22, 2016 - Operating Fee Methodology
April 22, 2016 - OTR Methodology
April 4, 2016 - Strategic Plan
March 22, 2016 - EGRPRA Review Part 4
March 16, 2016 - Request for NCUA to Reaffirm Commitment to Consider Good Faith Efforts
February 5, 2016 - FOM
January 21, 2016 - 18-Month Examination Cycle
NIST
September 9, 2016 - Current and Future States of Cybersecurity
February 3, 2016 - Improving Critical Infrastructure Cybersecurity
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Browse 2015 regulatory comment letters sent to agencies on behalf of NAFCU members.
CFPB
December 18, 2015 - Privacy Notices
December 8, 2015 - Top Priorities and Concerns
November 18, 2015 - Payday Lending
November 2, 2015 - Overdraft Study
September 30, 2015 - Overdraft Consumer Survey
August 28, 2015 - Complaint Narratives
July 13, 2015 - Student Loan Servicing
July 7, 2015 - TRID Effective Date Extension
May 26, 2015 - Compliment Database
May 18, 2015 - Credit Card Market Review
March 30, 2015- Safe Student Banking Scorecard
March 30, 2015- Small Creditor and Rural Areas Amendments
March 23, 2015 - Joint Trades Letter on Prepaids
March 16, 2015 - Mortgage Servicing
March 13, 2015 - Suspension of Submitting Credit Card Agreements
DOE
July 2, 2015 - Student Account Proposal
DOL
September 3, 2015 - Overtime Wage Proposal
FASB
June 30, 2015 - Prepaid Stored-Value Cards
FCC
September 25, 2015 - Motion to Intervene
August 31, 2015 - ABA Petition
FHFA
July 27, 2015 - House Price Index
January 12, 2015 - FHLB Membership Requirements
FinCEN
November 2, 2015 - AML Rule for Investment Advisers
FRB
HUD
September 30, 2015 - Application for FHA Insured Mortgages
September 8, 2015 - FHA Insurance Filing Deadline
July 14, 2015 - Application for FHA Insured Mortgages
NCUA
November 20, 2015 - Bank Notes
November 12, 2015 - 2016 Budget
October 28, 2015 - CUSO Registry
October 5, 2015 - Supplemental Capital
September 21, 2015 - Economic Growth Regulatory Paperwork Reduction Act (EGRPRA)
September 18, 2015 - FFIEC Self Assessment Tool
August 31, 2015 - Member Business Loans and Commercial Lending
August 18, 2015 - 18 Month Exam Cycle
August 10, 2015 - Diversity Standards
August 3, 2015 - 2015 Regulatory Review
July 13, 2015 - Mid-Year Budget Review
July 13, 2015 - Share Insurance
June 11, 2015 - CLF Bridge Loans
May 13, 2015 - FOM Recommendations
May 4, 2015 - Small Entity Definition
April 29, 2015 - Fixed Asset Proposal
April 23, 2015 - Risk-Based Capital Proposal
April 6, 2015 - Response to NCUSIF Reform Recommendations
March 27, 2015 - Capital Planning and Stress Testing Schedule Shift
March 19, 2015 - Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA)
March 6, 2015 - Examination for TILA RESPA Compliance
February 23, 2015 - Risk Mitigation Plan
January 5, 2015 - Proposed Rule Regarding Corporate Credit Unions
NACHA
February 6, 2015 - NACHA Same Day ACH
DOT
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CFPB
November 10, 2014 - Amendments to the TILA/RESPA Integration
October 29, 2014 - Home Mortgage Disclosure (Regulation C)
September 22, 2014 - Disclosure of Consumer Complaint Narrative Data
September 16, 2014 - Joint Trade letter on TILA/RESPA implementation
September 10, 2014 - Use of Mobile Financial Services
July 14, 2014 - Regulation P Annual Privacy Notices
July 7, 2014 - Amendments to 2013 Mortgage Rule: Debt to Income Ratio and Small Creditor Definition
June 6, 2014 - Regulation E: Remittance
June 5, 2014 - Amendments to 2013 Mortgage Rules Under the Truth in Lending Act (Regulation Z)
April 1, 2014 - Remittance Transfers Defining Larger Participants of the International Money Transfer Market
February 28, 2014 - Comment on ANPR on Debt Collection
February 10, 2014 - Mortgage Closing ProcessJanuary 8, 2014 - Mortgage Rules ImplementationDoD
December 23, 2014 - Terms of Consumer Credit Extended to Service Memebers and Dependents
December 22, 2014 - Joint Credit Union Industry letter on Terms of Consumer Credit Extended to Service Members and Dependents
October 22, 2014 - Terms of Consumer Credit Extended to Service Members and DependentsFED
September 2, 2014 - Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA)
May 2, 2014 - Availability of Funds and Collection of Checks
February 7, 2014 - PSR and Procedures for Measuring Daylight Overdraft
February 10, 2014 - Regulation JFHFA
October 28, 2014 - Housing Goals
October 14, 2014 - Single Security
September 15, 2014 - Strategic Plan for Fiscal Years 2015 through 2019
September 8, 2014 - Input on the Guarantee Fees that Fannie Mae and Freddie Mac Charge Lenders
September 4, 2014 - Extension of comment period of proposed membership requirements for Federal Home Loan Banks
May 16, 2014 - National Mortgage Database ProjectFinCEN
October 3, 2014 - Consumer Due Diligence
NACHA
October 31, 2014 - Proposal on Compliance and Operational Topics
January 13, 2014 - Improving ACH Network Quality
January 13, 2014 - ACH Network Risks and Enforcement TopicsNCUA
December 24, 2014 - Flood Insurance
December 17, 2014 - Risk-Based Capital
December 16, 2014 - Policies and Procedures for Safeguarding Credit Union Data
November 6, 2014 - 2015 Budget
October 10, 2014 - Fixed Assets
October 9, 2014 - Examination Issues
September 29, 2014 - Thank You Letter to Chairman Matz on second comment period for risk-based capital
September 26, 2014 Letter on DOD Proposed Military Lending Cap Expansion- Finance Charges
September 2, 2014 -Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA)
August 25, 2014 - Securitizations
August 25, 2014 - Appraisals
August 4, 2014 - Regulatory Review
July 28, 2014 Mid-Year Budget Review
July 14, 2014 - Bylaws
June 30, 2014 - Associational Common Bonds
June 9, 2014 - Interagency proposed minimum requirements for Appraisal Management Companies
May 28, 2014 - NCUA Associational Group Quality Assurance Review
May 27, 2014 - Proposed rule on Risk-Based Capital
May 2, 2014 - Voluntary Liquidation Proposal
April 21, 2014 - Capital Planning and Stress Testing
April 18, 2014 - Joint Letter to NCUA from NAFCU and CUNA to extend comment period for Risk-Based Capital proposed rule
March 5, 2014 - MBL amendments and improvements
February 28, 2014 - Request to extend comment period for Risk-Based Capital proposed rule
February 7, 2014 - Proposed Diversity Policies
January 28, 2014 - Risk-Based Capital
January 23, 2014 - Exam Sites
January 17, 2014 - Federal Credit Union Loan Interest Rate Ceiling
January 17, 2014 - 2014-2017 Strategic Plan
January 13, 2014 - Data SecurityWhite House
April 14, 2015 - Open Seat on Federal Reserve's Board of Governors