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CUNA Comment Letters

CUNA Comments on CFPB Proposal re Disclosure of Consumer Complaint Data

On July 18, the Credit Union National Association (CUNA) filed a comment letter with the Consumer Financial Protection Bureau (CFPB) in response to its proposed policy statement on the disclosure of consumer complaint data. Under the proposal, the CFPB would duplicate its final policy statement on the disclosure of credit card complaint data for the disclosure of complaint data related to other types of financial products and services. While the final and proposed policy statements apply only to those institutions with at least $10 billion in assets, we expressed to the CFPB our concern that other federal financial regulators may follow the Bureau’s lead with regard to disclosure of complaint data. In that connection, CUNA suggested the Bureau continue to take proactive steps to coordinate with the other regulators and to minimize regulatory burdens, especially for smaller credit unions.

Further, in their letter, CUNA reiterates the comments in their January letter to the CFPB regarding the disclosure of credit card complaint data, which opposed the public release of certain complaint information that is separate from and in addition to the Bureau’s periodic reports and analyses that provide more complete complaint information to consumers.

The Bureau has implemented a tool on its website to allow public access to the complaint database, which currently includes only data related to credit card complaints. The Bureau has indicated its intention to essentially add to its public online database complaint information related to non-credit card complaints (for institutions with at least $10 billion in assets). Similar to the final policy statement, under the proposal, the Bureau will make available on the public online database only “non-narrative” data that does not contain confidential information. CUNA asked the Bureau to consider the potential benefits of including certain “narrative” information, which includes the consumer’s description of “what happened” and assessment of a “fair resolution,” as well as the institution’s written response to the complaint.

CUNA Comment Letter to CFPB on Non-Depository Institutions that Pose Risks to Consumers

Early the week of July 23, the Credit Union National Associaiton (CUNA) will submit a comment letter to the Consumer Financial Protection Bureau (CFPB) regarding its proposed procedures to supervise non-depository institutions that pose risks to consumers.  CUNA strongly agrees that non-depository institutions that pose risks to consumers with regard to consumer financial products or services should be subject to rigorous consumer protection supervision, regulation, and enforcement, as contemplated by the Dodd-Frank Act.  They generally agree with the proposed procedures that will ensure these entities have few opportunities to take advantage of consumers.  Further, CUNA continues to urge the agency to identify any remaining gaps in coverage in the consumer finance markets.  Section 1024 of the Dodd-Frank Act provides the CFPB with regulatory authority to supervise non-depository institutions that pose risks to consumers, in addition to the agency’s authority to supervise non-depository mortgage originators, mortgage brokers, payday lenders, and private education lenders regardless of size, as well as other non-depository providers that are “larger participants” in their respective markets.