The League has submitted comment letters on the following issues, which were informed by you, our members. Thank you for your participation in this important advocacy work as we make strides to reducing credit union’s regulatory burden. Where possible, we’ve included links and information regarding the current status of each issue. For more information on any of these issue, please contact our compliance department.
2026 | 2025 | 2024 | 2023 | 2022 | 2021
– 2022 –
NCUA: Cyber incident notification requirements
The League’s comments
The League submitted a comment letter, on Sept. 26, 2022, generally supporting a proposed NCUA rule that would require a federally insured credit union (FICU) to notify the agency within 72 hours after a “reportable cyber incident” (such as computer hacking or a ransom malware attack). “Prompt reporting can alert regulators to new threats,” we wrote, “helping the industry as a whole head off potentially catastrophic consequences quickly and efficiently.” However, we urged the NCUA not to shorten the reporting deadline to 36 hours – a standard that federal banking regulators have recently imposed. We argued that the 72-hour deadline is “more reasonable and realistic,” especially for smaller FICUs with limited resources and small staffs.
CDFI Fund: Certification Application changes
The League’s comments
On Dec. 5, 2022, The League joined other trades and credit unions in opposing the Community Development Financial Institution (CDFI) Fund’s proposed updates to its Certification Application. The proposal includes some provisions that will help the Fund ensure that CDFIs have strong community development missions and offer responsible products and services; however, other provisions would not only make it impossible for some fully eligible regulated depositories to recertify but would also substantially increase the compliance cost of being a certified CDFI. The updated Certification Application also fails to acknowledge the substantial benefits that CDFI-certified credit unions offer to their members and instead imposes requirements that will be nearly impossible to implement.
CFPB seeks information on so-called “junk fees”
The League’s comments
In April 2022, The League filed a letter with the CFPB, in response to their request for information about so-called “junk fees” charged by providers of consumer services. We explained that as not-for-profits, credit unions exist to serve their member-owners, not to profit from them with unreasonable fees. The fees we charge to consumers are disclosed in advance, not surprise fees that consumers have no choice but to pay. And the fees are reasonable, designed to offset the legitimate costs credit unions incur in providing certain services. We told the regulators that we strongly disagree with their mischaracterization of certain charges as hidden, inflated, “junk fees.”
FinCEN: Review of BSA regulations & guidance
The League’s comments
On Feb. 14, 2022, The League commented on FinCEN’s request for information regarding its BSA rules. We asked the federal agency to consider increasing the dollar threshold at which credit unions are required to file Currency Transaction Reports (CTRs) for members’ cash transactions. “It defies explanation that the $10,000 threshold for filing a CTR has not changed since it was established in 1972 – 50 years ago – despite increases in inflation and the cost of living,” we wrote. “These days, reporting every cash transaction of more than $10,000 means that credit unions are often capturing routine and innocent transactions that are of little or no significance for law enforcement.” We suggested that a $30,000 threshold would be more appropriate, with periodic reviews going forward.