Links in “Proposals, Requests, & Comments”

Many credit unions believe the proposed DOD lending rule will not affect them because they either have very few servicemembers in their membership or they don't have any products that are over the 36% lending cap. Unfortunately, neither of those facts have a major impact on the compliance burden caused by the proposed rule. [11/24/14]

NCUA announced that it will issue its revised risk-based capital rule at its January 15 board meeting. Chairman Matz stated that the revised proposed rule will have a 90-day comment period. [11/24/14]

NCUA Board member Mark McWatters is urging the NCUA Board to permit public comment on the agency’s budget proposal saying it would not compromise the Board’s independence. McWatters voted against the 2015 budget at the November board meeting. [11/24/14]

The NCUA will be revising the risk-based capital rule in January of 2015. Along with the revision will be a second comment period. [11/24/14]

If you consider the 900-page proposed rule as an indication that the CFPB is very concerned about prepaid debit cards and other prepaid accounts, you would be right!  Read this blog to get an understanding of the enhanced scope of this rule and how it could impact your operations. [11/18/14]

The proposed rule on prepaid accounts just issued by the CFPB has been expanded from the 2012 proposed rule to include a wider range of accounts.  In addition to the use-anywhere prepaid cards, the proposed rule also covers such things as campus cards used for financial aid disbursements, some government-benefits cards, tax-refund cards, and prepaid cards that some companies use to pay employees. CFPB Director Richard Cordray added that prepaid accounts are more than just cards and include other types of accounts, such as PayPal, Google Wallet and possibly certain mobile payment plans. [11/14/14]

After receiving only three comments regarding its proposed policy on payment system risk, the Federal Reserve Board is adopting the policy as it was proposed with an overall effective date of December 31, 2014. [11/13/14]

The CFPB is proposing to relax the timing requirements for creditors to redisclose interest rate–dependent charges and loan terms from the same day to the next business day. ABA appreciates the thought, but argues that unless that timeframe is pushed to three days, it would create consumer disadvantages and burden lending operations needlessly. [11/12/14]

Its time for EGRPRA (aka Economic Growth and Regulatory Paperwork Reduction Act of 1996). The every decade process of reviewing regulations will begin with the first meeting in Los Angeles on December 2, 2014 and continue throughout 2015. The meeting gives interested parties an opportunity to present their views on any of the 12 categories of regulations that covers safety and soundness areas, money laundering, consumer protection, etc. Need more? Go to http://egrpra.ffiec.gov/. [11/7/14]

Now that interest rate risk is being removed from the revisions to the proposed RBC rule, NAFCU is urging that NCUA make four other changes: lowering the 10.5% RBC ratio; removing the individual minimum capital requirement and creating an independent appeals process that is free of examiner retaliation; including a consideration of a credit union’s portfolio of assets and liabilities in the definition of a complex credit union; and increasing the 1.25% risk to assets ratio for ALLL purposes. [11/6/14]