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.

21-EA-14: NCUA - Compliance with BSA/AML and OFAC

On April 12, 2021, the National Credit Union Administration (NCUA) Board along with the Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board), Federal Deposit Insurance Corporation (FDIC), and Financial Crimes Enforcement Network (FinCEN) (collectively the agencies) published a request for information (RFI) seeking information and comment on the extent to which the principles discussed in the Interagency Supervisory Guidance on Model Risk Management (MRMG) support compliance by banks with the Bank Secrecy Act/anti-money laundering (BSA/AML) and Office of Foreign Assets Control (OFAC) requirements.

21-EA-13: CFPB: Protections for Borrowers Affected by COVID-19 Under RESPA

On April 9, 2021, the Bureau of Consumer Financial Protection (Bureau or CFPB) published a notice of proposed rulemaking (NPRM) to protect borrowers affected by the COVID-19 pandemic under the Real Estate Settlement Procedures Act (RESPA) or Regulation X.

21-EA-11: NCUA - Artificial Intelligence

On March 31, 2021, the National Credit Union Administration (NCUA) along with other federal banking agencies (collectively the Agencies) issued a joint request for information (RFI) to solicit comment on artificial intelligence (AI) and machine learning (ML) usage within the financial sector.

21-EA-12: FinCEN: Beneficial Ownership Reporting Requirements

On April 5, 2021, the Financial Crimes Enforcement Network (FinCEN) published an advanced notice of proposed rulemaking (ANPR) to solicit feedback related to beneficial ownership reporting requirements implementing section 6403 of the Corporate Transparency Act, which was enacted as part of the National Defense Authorization Act (NDAA).

21-EA-10: Department of the Treasury - Emergency Capital Investment Program

On March 9, 2021, the U.S. Department of the Treasury (Treasury) issued an interim final rule (IFR) to implement statutory eligibility requirements for the Emergency Capital Investment Program (ECIP), which was authorized by the Consolidated Appropriations Act, 2021 (CAA).

21-EA-09: CFPB - General QM Loan Definition; Delay of Mandatory Compliance Date

On March 5, 2021, the Bureau of Consumer Financial Protection (Bureau or CFPB) published a notice of proposed rulemaking (NPRM) to delay the mandatory compliance date of the General Qualified Mortgage (QM) loan definition until October 1, 2022.

21-EA-08: NCUA - Simplification of Risk-Based Capital Requirements

On January 14, 2021, the National Credit Union Administration (NCUA) issued an advanced notice of proposed rulemaking (ANPR) to simplify the risk based capital requirements found in the agency’s 2015 Final Risk Based Capital Rule (RBC rule).

21-EA-07: NCUA - CAMELS Rating System

On January 14, the National Credit Union Administration (NCUA) Board approved for publication a proposed rule to add an “S” component to the existing CAMEL rating system and to redefine the “L” component to distinguish liquidity risk from sensitivity to market risk.

21-EA-06: NCUA - Credit Union Service Organizations

On January 14, 2021, The National Credit Union Administration (NCUA) Board issued a proposed rule which seeks comment on the amendment of the NCUA’s credit union service organization (CUSO) regulation. The NCUA is also seeking comment on broadening Federal Credit Union (FCU) investment authority in CUSOs.

21-EA-05: NCUA - Risk-Based Net Worth – COVID-19 Regulatory Relief

On January 14, 2021, the National Credit Union Administration (NCUA) issued a proposed rule to amend the definition of “complex” for purposes of being subject to any risk-based net worth (RBNW) requirement in part 702 of the NCUA’s regulations. To learn more, please read NAFCU's Regulatory Alert.