Proposed Regulation

NAFCU Regulatory Alerts are member-only resources containing important highlights and summaries for proposed rulemakings that affect credit unions. Each alert PDF also provides a link to send NAFCU comments that we will include in our letter to the agency or agencies that issued the proposed rule.

20-EA-20: NCUA - Derivatives

On October 15, 2020, the National Credit Union Administration (NCUA) approved a notice of proposed rulemaking (NPRM) to be published in the Federal Register amending Subpart B to Part 703 of the regulations regarding derivatives.

20-EA-19: Consumer Financial Protection Bureau - Section 1071 – Outline of Proposals Under Consideration

On September 15, 2020, the Consumer Financial Protection Bureau issued an outline of proposals (Outline) under consideration to implement small business lending data collection requirements under Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).

20-EA-18: Financial Crimes Enforcement Network: Anti-Money Laundering Program Effectiveness

On September 17, 2020, the Financial Crimes Enforcement Network (FinCEN) issued an advanced notice of proposed rulemaking (ANPR) soliciting comments on regulatory amendments to establish that all financial institutions subject to anti-money laundering (AML) requirements must maintain an “effective and reasonably designed” AML program.

20-EA-17: NCUA - Interagency Questions and Answers Regarding Flood Insurance

On September 3, 2020, the National Credit Union Administration (NCUA), along with the Office of Comptroller of the Currency, the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Farm Credit Administration (collectively, “the agencies”) published a proposed rule to reorganize, revise, and expand the Interagency Questions and Answers Regarding Flood Insurance (“Interagency Questions & Answers”), last updated in 2011.

20-EA-16: CFPB - Seasoned Qualified Mortgage Definition

On August 18, 2020, the Bureau of Consumer Financial Protection (Bureau or CFPB) issued a notice of proposed rulemaking (NPRM) creating a new seasoned qualified mortgage (QM) definition under the Truth in Lending Act (TILA).

20-EA-15: NCUA - Fees Paid by Credit Unions

On July 30, 2020, the National Credit Union Administration (NCUA) issued a request for comment (RFC) on the agency’s existing Overhead Transfer Rate (OTR) methodology and proposed clarifications regarding how the methodology is applied to apportion operating fees charged to federal credit unions (FCUs).

20-EA-14: NCUA - Overhead Transfer Rate Methodology and Operating Fee Schedule Methodology

On July 30, 2020, the National Credit Union Administration (NCUA) issued a request for comment (RFC) on the agency’s existing Overhead Transfer Rate (OTR) methodology and proposed clarifications regarding how the methodology is applied to apportion operating fees charged to federal credit unions (FCUs).

20-EA-13: NCUA - Transition to CECL

On July 30, 2020, the National Credit Union Administration (NCUA) issued a proposed rule to establish a three-year phase-in of the day-one adverse impacts of the Current Expected Credit Loss (CECL) accounting standard on a federally-insured credit union’s (FICU) net worth ratio.

20-EA-12: CFPB - Equal Credit Opportunity Act and Regulation B

On August 3, 2020, the Consumer Financial Protection Bureau (CFPB or Bureau) published a request for information (RFI) inviting comment on opportunities to prevent credit discrimination, encourage responsible innovation, promote fair, access to credit, address uncertainty, and develop viable solutions to regulatory compliance challenges under the Equal Credit Opportunity Act (ECOA) and Regulation B.

20-EA-11: CFPB - Higher-Priced Mortgage Loan Escrow Exemption

On July 22, 2020, the Bureau of Consumer Financial Protection (Bureau or CFPB) published an notice of proposed rulemaking (NPRM) amending Regulation Z, which implements the Truth in Lending Act (TILA) as mandated by the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA).