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NAFCU Chief Economist and Vice President of Research Curt Long testified at the NCUA’s budget hearing, requesting the agency find cost cutting measures to limit the “unsustainable” budget increases. Of note, the NCUA proposed an increase of 9.5 percent from 2023 and an increase of 9.9 percent from the 2024 proposed budget for 2025.

In mid-November, Congress passed another continuing resolution to fund the government into next year. The bill expires on separate dates for certain agencies, with funding lasting until Jan. 19 or Feb. 2, depending on the agency.

In addition, NAFCU Senior Vice President of Government Affairs Greg Mesack responded to the Fed’s interchange proposal with an op-ed in CU Insight.

Watch NAFCU’s latest update video as Mesack provides need-to-know information from November. 

Meetings 

·       November 28: NAFCU’s Amanda Smith and representatives from other financial services trade associations met with FCC Commissioner Anna Gomez and her staff to discuss the commission’s proposal on consumers’ revocation of consent to receive automated calls and texts and the importance of allowing credit unions to continue to communicate important and timely information to their members. 

·       November 6: The NAFCU Board met with Federal Reserve Gov. Michelle Bowman to discuss important credit union issues, including opposition to the Federal Reserve’s proposal to reduce the debit interchange fee cap, and the work credit unions do to provide financial services to low- and moderate-income households.

Bills 

·       NAFCU and CUNA wrote to the House in support of S.J.Res. 32, a resolution of disapproval of the CFPB’s Section 1071 small business lending data collection rule under the Congressional Review Act. This legislation previously passed the Senate; the House is set to vote on the resolution Friday, Dec. 1. 

·       The House began consideration of H.R. 4664, the Financial Services and General Government (FSGG) appropriations bill for Fiscal Year 2024. NAFCU wrote in support of some of the bill’s policy provisions, including changing the CFPB’s governance structure to a bipartisan commission and making the bureau subject to the annual appropriations process. NAFCU also advocated for increased funding for the Community Development Financial Institutions (CDFI) Fund and Community Development Revolving Loan Fund and reiterated our opposition to the development of a central bank digital currency. The bill was pulled from consideration before coming to a vote.

Hearings 

·       November 30 and November 29: The Senate Banking Committee and House Financial Services Committee held CFPB oversight hearings with Director Rohit Chopra. NAFCU and CUNA wrote to each committee to share our support for changing the Bureau’s governance structure to a bipartisan commission and to highlight key credit union issues before the CFPB, including tailoring its regulations to reduce burdens on community institutions, increasing transparency and consistency, expanding oversight of fintechs, “junk fees,” and more. 

·       November 16: NAFCU’s Curt Long testified on NAFCU’s concerns with the unsustainable pace of the agency’s budget increases during the NCUA’s budget hearing on its proposed 2024-2025 budget. NAFCU also submitted written comments. 

·       November 15 and November 14: The House Financial Services Committee and Senate Banking Committee held hearings on oversight of prudential regulators, including the NCUA. NAFCU and CUNA wrote to each committee to share our thoughts on key NCUA issues and advocate for continued parity in deposit insurance levels between the NCUA and FDIC. The organizations also expressed strong opposition to the Federal Reserve’s proposal to lower the debit interchange fee cap. 

·       November 15: The Senate Small Business Committee held a hearing on veteran entrepreneurship. NAFCU wrote to the committee to share our support for S. 539, the Veterans Member Business Loan Act, which would exempt loans made to veterans from the credit union member business lending cap.

Comment Letters 

·       November 22: NAFCU and other financial services trade associations wrote to the Federal Reserve to request an extension of the comment period for the proposed reduction to the debit interchange fee cap. In addition, Mesack published an op-ed in CU Insight Nov. 29 calling the Fed’s proposal “an attempt to solve a non-problem.” 

·       November 21: NAFCU wrote to the NCUA in response to the agency’s proposed 2024-2025 budget, expressing opposition to the significant Operating Budget increase and proposed increase to the NCUA’s staffing level. Additionally, NAFCU encouraged the NCUA to find additional cost saving opportunities and offset necessary increases elsewhere in the budget. 

·       November 7: NAFCU wrote to the Department of Labor in response to its proposed rule on exemptions for minimum wage and overtime pay, encouraging the department to consider the impact of the proposal on small credit unions and opposing future automatic adjustments to salary exemption levels. 

·       November 6: NAFCU and CUNA wrote to the CFPB in response to the bureau’s outline of proposals for a rulemaking under the Fair Credit Reporting Act (FCRA). The CFPB is proposing to require financial institutions to investigate legal as well as factual disputes of information in credit files and to restrict the use of medical debt information in credit decisions, among other changes.

Regulatory Alerts and Final Regulations 

·       November 27: NAFCU published a Final Regulation Summary on the NCUA’s charitable donation accounts (CDAs) rule. The final rule will add veterans’ organizations under Section 501(c)(19) of the Internal Revenue Code to the NCUA’s definition of “qualified charity.” NAFCU, the Defense Credit Union Council, the Veterans of Foreign Wars, and TruStage (formerly CUNA Mutual Group) originally requested this change in November 2022 and wrote in support of the proposed rule in July 2023. 

·       November 13: NAFCU published a Regulatory Alert on the CFPB’s proposal to define “larger participants” in the market for general-use consumer payment applications, a step toward reducing regulatory gaps between credit unions and fintechs. 

·       November 8: NAFCU published a Regulatory Alert on FinCEN’s proposal to implement recordkeeping and reporting requirements for financial institutions for transactions known or suspected to involve convertible virtual currency (CVC) mixing, which is a process intended to obfuscate the source, destination, or amount involved in a CVC transaction.