This week marks the end of the comment period regarding the NCUA's regulatory review process for 2016, a rolling review of the regulator's policies and rules. Also due for comments this week are various information collection procedures by regulators, as well as the Consumer Financial Protection Bureau's annual privacy notice rule.
NCUA Regulatory Review and Information Collection
Comments are due this week on Aug. 8 regarding the NCUA's 2016 Regulatory Review, a three-year process that the regulator undertakes to "ensure that all of our regulations are clearly articulated and easily understood."
The group of regulations up for review this period are as follows:
- 711 – Management Official Interlocks
- 712 – Credit Union Service Organizations (CUSOs)
- 713 – Fidelity Bond and Insurance Coverage for Federal Credit Unions
- 714 – Leasing
- 715 – Supervisory Committee Audits and Verifications
- 717 – Fair Credit Reporting
- 721 – Incidental Powers
- 722 – Appraisals
- 723 – Member Business Loans
- 724 – Trustees and Custodians of Certain Tax-Advantages Savings Plans.
The NCUA has submitted a request for comment regarding information collection for its written reimbursement policy. According to the Federal Register, "Each FCU must draft a written reimbursement policy to ensure that the FCU makes payments to its director within the guidelines that the FCU has established in advance and to enable examiners to easily verify compliance by comparing the policy to the actual reimbursements."
Comments are due 60 days after the posting on Oct. 7 of this year.
CFPB Proposals Due for Comment
Comments are due on Aug. 11 for the CFPB's amendment to the Annual Privacy Notice requirement under the Gramm-Leach-Bliley Act. According to amendments under the GLB Act, financial institutions are no longer required to provide annual privacy notices as long as they have not changed their privacy policies since last notice sent and they only share information in a manner that is exempt from notice and opt-out requirements. According to the CFPB, the bureau looks to make "minor technical modifications and clarifications" to the rule.
Also due on Aug. 11 are comments regarding the CFPB's request to renew the Office of Management and Budget's approval for information collection titled, "Consumer Advisory Boards, Groups and Committees.
Legislative Summit – National Congress of State Legislatures
The National Congress of State Legislatures is holding its legislative summit this week in Chicago. Ryan Donovan, chief advocacy officer with the Credit Union National Association, said that the trade group and representatives from various state leagues "will be advocating to state lawmakers on behalf of credit unions and members."
According to Donovan, the summit includes standing committees that will consider policies, recommendations and proposals on subjects including dual chartering, tax status and data security. Donovan mentioned there is a "high threshold" for policy proposals to be approved, "[There is] a really positive policy on dual charter and tax status," he said, adding there is little concern on changes to those policies.
Joining CUNA at the summit are representatives from leagues, including Illinois, Ohio, Kentucky, Minnesota, Georgia, the Cornerstone League, Tennessee, New Mexico and the Cornerstone CU League, which represents Texas, Oklahoma and Arkansas.
NAFCU's Risk Management Seminar
The National Association of Federal Credit Unions will be holding a Risk Management Seminar this week in Denver. The seminar includes sessions focusing on topics related to data security, fraud and other risk management subjects.
NCUA's cyber examiner Tim Segerson will be presenting a risk roadmap at the seminar. Also included in the seminar are sessions focusing on enterprise risk management (ERM) models, ERM methodology and NCUA regulatory guidance, and an optional certification for NAFCU's Certified Risk Manager program.
Upcoming Proposals to Look Out For
- Comments due Aug. 15 – CFPB information collection practices regarding Truth in Savings
- Comments due Aug. 15 – NCUA Call Report Modernization feedback deadline on structure of call reports
- Comments due Aug. 22 – CFPB regulations concerning arbitration agreements
- Comments due Aug. 22 – NCUA's Community Development Revolving Loan Fund technical changes.
