Links in “Proposals, Requests, & Comments”
- NAFCU Asks for Additional 60 Days on FHLB Proposal
NAFCU CEO Dan Berger has asked the Federal Home Loan Bank Board to give credit unions another 60 days to submit comments on the FHLBâs proposed changes to its membership eligibility requirements. Berger said that the proposal is complex and credit unions need more time to analyze the impact of the proposed changes. [9/5/14]
- CFPB Issues a HMDinger of a Proposal
The CFPB is publishing a proposed amendment to Regulation C (HMDA) for public comment. The changes focus on adding and clarifying several reporting elements for institutions, as well as amending institutional and transactional coverage under the regulation. The public comment period is open through October 29, 2014. [8/29/14]
- NASCUS Comment Calls Residual Interest Rate “Too Restrictive”
In response to the NCUA's proposed changes to NCUA Rules and Regulations Parts 721 and 741, NASCUS addressed a number of other issues regarding the dual chartering system for credit unions. One such comment recommended that the NCUA be more flexible rather than use the 25 percent limit as a blanket restriction. [8/28/14]
- Being Young Is Getting More Complicated
A proposed rule regarding parental verification is seeking public comment. This rule would require that parents give permission before online sites and services are able to collect personal information from their child. [8/26/14]
- CUs Should Be Excluded from FASB Loss Reporting Proposal
Thatâs the position being taken by CUNA Acting President/CEO, Bill Hampel. The proposed rule would utilize a single "expected loss" measurement for the recognition of credit losses, replacing the multiple existing impairment models currently in use that primarily use an "incurred loss" approach. In a letter to FASB, Hampel argues that the proposed changes could have a âsignificant detrimentalâ impact on credit unions. [8/22/14]
- FinCEN Is NOT among Summer Slackers
With a proposed rule and multiple advisories and announcements over the past few months, FinCEN has kept extremely busy. It can be a handful to remember, but this article provides a summary of FinCEN's hottest announcements this summer. [8/15/14]
- Congressional Concern Likely to Impact Final RBC Rule
Due to the significant amount of concern expressed by Congress on NCUAâs proposed risk-based capital rule, NCUA will want to tread carefully in crafting the final rule, according to Carrie Hunt, General Counsel for NAFCU. If the final rule does not satisfactorily address the issues raised by members of the House and Senate, the end result could be legislation that could affect the degree of flexibility the agency has in the future. [8/14/14]
- Attention: State-Chartered Credit Unions
NCUA's fixed-asset proposal could apply to you! Find out here. [8/13/14]
- Raising $105M for RBC
Oklahoma Senator James Inhofe recently wrote the NCUA expressing his concerns about the proposed risk-based capital rule, including the estimation that Oklahoma credit unions would have to raise about $105M to just meet the capital requirements. What would your institution have to do to keep up with RBC? [8/12/14]
- If It Ainât Broke, Donât Fix It
FinCEN has proposed a renewal of suspicious activity reporting requirements. Thankfully, no changes are proposed, but comments are welcome. [8/11/14]