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Comment Letter Deadlines Approach

Time is running out to submit comment letters on several key issues affecting credit unions.  The Missouri Credit Union Association (MCUA) encourages credit union advocates to send in comment letters if possible. If you have any questions, please contact the MCUA Compliance department via email or phone, 800.446.3620.

Federal Home Loan Bank (FHLB) Membership - Comments due to FHFA by January 12

The Federal Housing Finance Agency (FHFA) issued a proposed rule that would make regulatory changes to Federal Home Loan Bank (FHLB) membership rules. The proposed rule requires that the initial FHLB membership requirements be met continuously. FHLB members found to be out of compliance would be given one year to return to compliance. 

Click here for more details.

Military Lending Act Proposed Rule - Comments due to DoD by December 26

The Department of Defense (DoD) issued a proposal to amend its rule that implements the Military Lending Act (MLA). The proposal would significantly expand the scope of products covered by the MLA, including credit cards. Specifically, the proposal would amend “consumer credit” to extend the definition to a broader range of closed-end and open-end credit products; the proposed definition is consistent with that of the Truth-in-Lending-Act (TILA), as implemented by the Consumer Financial Protection Bureau's (CFPB) Regulation Z.

The proposal would also amend provisions of DoD’s rule regarding the manner in which a creditor can assess whether a consumer is a “covered borrower.” In addition, the proposal would modify disclosures that a creditor must provide a covered borrower, as well as implement enforcement provisions of the MLA.

MCUA filed a comment letter with the DoD on November 25. Click here to read the full letter.

Corporate Credit Unions - Comments due to NCUA by January 5

The National Credit Union Administration's (NCUA) proposed rule would make a number of changes to the definitions of Part 704, the agency's corporate credit union regulation, along with a few changes to other sections.  In their comment letter, the Credit Union National Association (CUNA) will raise concerns about issues related to corporates credit unions’ capital. 

Specifically the proposal would:

  • Base a corporate credit union’s lending limit on its total capital. (Currently a corporate’s unsecured member lending is limited to 50 percent of capital and its secured member lending to 100 percent of capital. (The unsecured limit would remain but would be based on total capital; the secured lending limit would be raised to 150% of total capital.)
  • Extend a corporate’s borrowing limit from 30 to 120 days. A longer term limit of one to two years might give corporates more flexibility in providing liquidity to credit unions.

There is concern that NCUA is hampering corporates’ ability to provide liquidity to the credit union system with requirements that do not allow corporates to use fully the capital that they have in place.  The rule would allow NCUA to apply a similar credit union service organization (CUSO) rule to corporates that is not in place for natural person credit unions. It would require that corporates implement an enterprise risk management program. 

Flood Insurance Proposed Rule - Comments due to NCUA by December 29

NCUA issued a proposed rule that would implement requirements under the Homeowner Flood Insurance Affordability Act of 2014, which modifies and improves some of the requirements from the Biggert-Waters Flood Disaster Protection Act.  MCUA supports the proposal, but will be seeking some clarifications.   Specifically this proposed rule would:

  • Modify escrow requirements by creating several exceptions. Most important is the exception from the rule for home equity lines of credit. Second mortgages would still be covered.
  • Create a detached structure exemption from mandatory escrow requirements.
  • Apply to loans entered into or outstanding on or after January 1, 2016.

Credit unions with less than $1 billion in assets will not be subject to the rule.  The rule does not impact forced place or private insurance requirements proposed in the 2013 flood insurance rule.