Links in “Proposals, Requests, & Comments”

Attorneys general from 20 states write to the Department of Defense to say that while its proposal to protect servicemembers from predatory lending is laudable, the proposal could do more on two fronts: the 36% military APR and loans deceptively structured as "secured" in name only. [12/23/14]

CFPB is proposing to amend Regulation E, Regulation Z, and the official interpretations to create comprehensive consumer protections for prepaid financial products. The proposal would cover prepaid accounts such as cards, codes, or other devices capable of being loaded with funds and usable at unaffiliated merchants or for person-to-person transfers and are not gift cards. See proposed rule here. [12/23/14]

Several trade associations write to the Department of Defense regarding the proposed changes to the Military Lending Act, warning that some of the proposals could end up segregating servicemembers and their families from "needed and beneficial mainstream credit products." [12/19/14]

Same-day ACH transfers may be a possibility under a new proposed rule issued by the Electronic Payments Association (NACHA). The proposed rule would allow two new same-day settlement windows for three ACH network settlements each day. This would mandate that RDFIs receive ACH files every business day and make the funds available to their depositors by the end of each business day. [12/18/14]

No one in the credit union industry is happy about the Federal Housing Finance Agency’s new proposed rule that would require credit unions to retain 10% of all of their assets in residential mortgages in order to retain their membership in the Federal Home Loan Bank system. All agree that, if adopted, the proposed the rule could significantly limit a valuable source of liquidity for credit unions. [12/15/14]

The CFPB is proposing more changes to the 2013 mortgage servicing rules. Among other things, the proposed changes include elements of force-placed insurance notices and periodic statement requirements found in RESPA and TILA. [12/15/14]

NCUA Board member Mark McWatters has confirmed to CUNA that he would support the addition of a provision in the proposed risk-based capital rule that would provide credit unions the opportunity to use supplemental capital to meet their RBC requirements. The NCUA Board is scheduled to take up the new proposed rule at its January 15^th meeting. [12/11/14]

The CFPB recently proposed far-reaching regulations that outline requirements for prepaid financial products. In addition, the proposed regulations regulate benefit cards, payroll cards, tax refund cards, student financial aid disbursement cards, as well as mobile and electronic accounts. [12/2/14]

The House is poised to take up a bill today that would trigger a study to reform Regulation D. Of most interest to credit unions is a consideration of either increasing or eliminating the 6-transaction cap, which is confusing for consumers and often causes unintentional overdrafts or returned checks. [12/2/14]

A look at the CFPB's proposed rulemaking on servicing rules under Regs. X & Z. [12/1/14]