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.

19-EA-17: NCUA - Delay of Effective Date of the Risk-Based Capital Rules

On June 26, 2019, the National Credit Union Administration (NCUA) published a proposal to delay the effective date of the NCUA's October 2015 final rule regarding risk-based capital (2015 Final Rule), along with its November 2018 supplemental final rule regarding risk-based capital (2018 Supplemental Rule), by two years until January 1, 2022.

19-EA-16: NCUA - Public Unit and Nonmember Shares

On May 30, 2019, the National Credit Union Administration (NCUA) published a proposal to amend its public unit and nonmember share rule to allow federal credit unions (FCUs) to receive public unit (e.g., the U.S. government, states, and political subdivisions therein) and nonmember shares up to 50 percent of the credit union's paid-in and unimpaired capital and surplus less any public unit and nonmember shares.

19-EA-15: CFPB - Debt Collection Practices

On May 21, 2019, the Bureau of Consumer Financial Protection (Bureau or CFPB) published a notice of proposed rulemaking (NPRM) to amend Regulation F, which implements the Fair Debt Collection Practices Act (FDCPA).

19-EA-14: CFPB - Regulatory Flexibility Act Plan for Review

On May 15, 2019, the Consumer Financial Protection Bureau (Bureau or CFPB) published a request for comments in connection with the Bureau’s plan for required review of its rules under section 610 of the Regulatory Flexibility Act (RFA). The RFA requires the Bureau to periodically consider whether a significant rule should be continued without change, amended, or rescinded to minimize any significant economic impact on a substantial number of small entities.

19-EA-13: Federal Reserve - National Settlement Service and Fedwire Enhancements

On May 16, 2019, the Board of Governors of the Federal Reserve System (Board) published a notice and request for comments regarding proposed modifications to the Federal Reserve Banks' (Reserve Banks) payment services to facilitate adoption of a later same-day automated clearinghouse (ACH) processing and settlement window.

19-EA-12: CFPB - Home Mortgage Disclosure (Regulation C)

On May 13, 2019, the Bureau of Consumer Financial Protection (Bureau or CFPB) published a notice of proposed rulemaking (NPRM) to solicit comments on whether to make changes to the Home Mortgage Disclosure Act (HMDA) transactional and institutional thresholds that exempt smaller lenders from data reporting requirements under Regulation C.

19-EA-11: CFPB - Home Mortgage Disclosure Data Points and Coverage

On May 8, 2019, the Bureau of Consumer Financial Protection (Bureau or CFPB) published an advance notice of proposed rulemaking (ANPR) to solicit comments on whether to make changes to the Home Mortgage Disclosure Act (HMDA) data points that credit unions are required to report.

19-EA-10: CFPB - Regulatory Flexibility Act Review of 2009 Overdraft Rule

On May 15, 2019, the Bureau of Consumer Financial Protection (Bureau or CFPB) published a request for comments in connection with its required review of the 2009 Overdraft Rule under the Regulatory Flexibility Act (RFA). The RFA requires the Bureau to consider whether a significant rule should be continued without change, amended, or rescinded to minimize any significant economic impact on a substantial number of small entities. Accordingly, the Bureau seeks comment not only on burdens to credit unions but also consumer benefits associated with the rule.

19-EA-09: CFPB - Request for Information Regarding Potential Regulatory Changes to the Remittance Rule

On April 29, 2019, the Bureau of Consumer Financial Protection (Bureau or CFPB) published a request for information (RFI) regarding three principle issues related to the remittance transfer rule: (1) how the Bureau can mitigate the expiration of a useful statutory exception for providing estimates in prepayment disclosures, (2) whether to change the safe harbor threshold in the rule that determines whether a credit union makes remittance transfers in the normal course of business, and (3) whether an exception for small financial institutions may be appropriate.

19-EA-08: NCUA - Compensation in Connection with Loans to Members and Lines of Credit to Members

On April 23, 2019, the National Credit Union Administration (NCUA) published an advance notice of proposed rulemaking (ANPR) to solicit comments on ways to improve the NCUA’s regulations limiting a credit union official’s and employee’s compensation in connection with loans to members and lines of credit to members.