Newsroom
NAFCU writes to CFPB regarding 2022-2026 Strategic Plan
NAFCU Senior Regulatory Affairs Counsel Kaley Schafer Monday sent a letter to the CFPB in response to the bureau’s strategic plan for fiscal year 2022-2026. The CFPB first issued its proposed strategic plan in December 2021, detailing four strategic goals that will be carried out by various objectives.
The CFPB’s first goal is to implement and enforce the law to ensure consumers have access to fair, transparent, and competitive markets that serve consumers’ needs and protect consumers from unfair, deceptive, and abusive acts and practices (UDAAP), and from discrimination. In the letter, NAFCU urged the CFPB to “initiate a rulemaking to define the ‘abusiveness’ standard, or, alternatively, reinstate its previous policy statement clarifying the standard.”
Regarding the bureau’s objective to focus on supervision and enforcement resources to those that pose the greatest harm to consumers, the association supports this focus, but points out that size of an institution does not equate to risk. The CFPB should instead, “divert supervision resources to those actors or products that cause the greatest harm to consumers and are in violation of federal consumer financial laws,” suggested Schafer.
Schafer also encouraged the CFPB to remove or revise obsolete regulations to help credit unions deal with increased compliance burdens and increased compliance costs, which would allow them to focus more on serving their members. “Revising and removing outdated and conflicting regulations may better align with industry practices and consumer expectations, while simultaneously ensuring consumer safety,” noted Schafer.
On the CFPB’s second goal to empower consumers to live better financial lives with a focus on traditionally underserved people, Schafer noted that NAFCU credit union members and the industry as a whole, already focus on helping underserved communities through financial literacy and education programs. NAFCU suggests that the CFPB provide guidance or an advisory opinion on special purpose credit programs (SPCPs) focused on not-for-profit entities. The bureau can also empower consumers to live better financial lives through small-dollar lending.
“Often, credit unions offer short-term, small-dollar loans as a service to members with the associated fees solely covering the expenses of loan origination and servicing,” stated Schafer. “Regulations should be tailored to eradicate bad actors in the market without inhibiting credit unions’ ability to provide safe and affordable loans.”
NAFCU also provided suggestions on the CFPB’s goal to inform public policy with data-driven analysis on consumers’ experiences with financial institutions, products, and services, calling on the bureau to create a fair landscape between credit unions and fintechs or other companies offering financial services by providing more oversight and regulatory guidance on fintechs. The association also urges the CFPB to “ensure that P2P service providers are providing sufficient information for financial institutions to reasonably investigate alleged token errors, as described in the Bureau’s Fall 2021 Supervisory Highlight,” wrote Schafer.
The CFPB should also consider standards for ensuring that nonbank payment service providers are “responsive to credit union and other financial institution requests related to Regulation E investigations,” suggested Schafer. A structured regulatory framework would support coordination among all payment system participants.
NAFCU continues to remain engaged with the CFPB regarding its strategic plan and appreciates the bureau’s commitment to evaluate and adjust the plan as needed.
Share This
Related Resources
Add to Calendar 2024-04-25 14:00:00 2024-04-25 14:00:00 Unifying Two Different Executive Benefits Programs About the Webinar In part one we discussed how to retain key positions during a time of transition. In part two, we will look at how to combine executive benefits programs from two different organizations into a single high-performing program. Evaluating each program includes many different facets, from strategy and expense to performance and servicing. This session will provide important considerations, whether or not you have pending M&A activity. Key Takeaways: Is the plan design both retentive and efficient? Is the benefit expense properly mitigated? Does the legal agreement reflect the board’s intent? View On-Demand Web NAFCU digital@nafcu.org America/New_York public
Unifying Two Different Executive Benefits Programs
preferred partner
Gallagher
Webinar
Add to Calendar 2024-04-25 14:00:00 2024-04-25 14:00:00 ChatGPT: What AI can do for you! ChatGPT has been created with one main objective – to predict the next word in a sentence, based on what's typically happened in the gigabytes of text data that it's been trained on. Did you ever hear of the saying, “People fear the unknown?” Artificial intelligence scares people, but it is the future, and you need to understand the tools and resources it offers. It’s also about saving time, that’s what technology and in this case, artificial intelligence can do for you. If you want to save time and have a better quality of life, this training is for you. Once you give ChatGPT a question or prompt, it passes through the AI model and the chatbot produces a response based on the information you've given and how that fits into its vast amount of training data. It's during this training that ChatGPT has learned what word, or sequence of words, typically follows the last one in a given context. During this webinar, ChatGPT: What AI can do for you, you’ll discover the background, purpose, usability, and the pros and cons. Don't miss this opportunity! Key Takeaways Learn the background of AI Understand the purpose of AI Identify the pros and cons Register Now $295 Members | $395 Nonmembers(Additional $50 for USB)One registration gives your entire team access to the live webinar and on-demand recording until April 25, 2025Go to the Online Training Center to access the webinar after purchase » Who Should Attend NCRMs Risk titles Education Credits NCRMs will recieve 1.0 CEUs for participating in this webinar Web NAFCU digital@nafcu.org America/New_York public
ChatGPT: What AI can do for you!
Credits: NCRM
Webinar
Add to Calendar 2024-04-24 14:00:00 2024-04-24 14:00:00 Optimize Liquidity, Maximize Loan Growth: The Network Lending Advantage About The Webinar Join us to learn more about network lending, a cooperative model allowing credit unions to optimize liquidity and achieve loan growth. Discover how credit unions can participate in loan pools with other institutions, allowing them to diversify portfolios, access loans with potentially lower risk and higher yields, and expand lending capacity without necessarily needing a surge in deposits. Delve into how credit unions can pool their resources, set common underwriting and pricing standards, and collectively originate, buy, and sell loans to optimize liquidity management. Hear from your peers about best practices, case studies, and practical strategies to harness the full potential of network lending and how it's helped their credit unions. Don't miss this valuable opportunity to learn how to strengthen your credit union's position in today’s competitive environment. Key Takeaways: How network lending differs from traditional lending The benefits of participating in loan pools with other credit unions How credit unions can set common underwriting and pricing standards and collectively originate, buy and sell loans to optimize liquidity management Why network lending is critical to loan growth Watch On-Demand Web NAFCU digital@nafcu.org America/New_York public
Optimize Liquidity, Maximize Loan Growth: The Network Lending Advantage
preferred partner
LendKey
Webinar
Add to Calendar 2024-04-23 14:00:00 2024-04-23 14:00:00 Monitoring the Latest Litigation Risks Credit unions’ operations pose litigation risks, with more of these cases being filed as class action lawsuits. In this Monitoring the Latest Litigation Risks for Credit Unions webinar, you’ll review some of the specific kinds of lawsuits impacting credit unions and what potential claims could be on the horizon. You’ll also examine some options for mitigating risks. Key Takeaways Review the current lawsuit trends. Understand the potential claims risks Explore options for mitigating risks. Register Now $295 Members | $395 Nonmembers(Additional $50 for USB)One registration gives your entire team access to the live webinar and on-demand recording until April 23, 2025Go to the Online Training Center to access the webinar after purchase » Who Should Attend NCCOs NCRMs Compliance and risk titles Education Credits NCRMs will recieve 1.0 CEUs for participating in this webinar NCCOs will recieve 1.0 CEUs for participating in this webinar Web NAFCU digital@nafcu.org America/New_York public
Monitoring the Latest Litigation Risks
Credits: NCCO, NCRM
Webinar
Get daily updates.
Subscribe to NAFCU today.