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
– 2023 –
CFPB: Open banking proposal
The League’s comments
On Dec. 29, 2023, The League filed a comment letter with the CFPB, voicing Wisconsin credit unions’ opposition to a proposed federal “open banking” rule. Among other things, it would require most credit unions and other financial institutions to give a consumer certain data relating to that consumer’s transactions and accounts, and to share that data with third parties (including other businesses that offer competing products) at no cost – if the consumer asks for it. Our letter stressed that the CFPB’s proposal goes too far and that it would present real dangers to members’ privacy and security, as well as significant expenses and compliance burdens for credit unions.
Final rule issued
No
NCUA: Proposed “quality control” rule for mortgage originators
The League’s comments
On Aug. 21, 2023, The League filed a comment letter on the federal regulators’ proposal to impose quality control standards on users of “automated valuation systems” (AVMs) in mortgage lending. We want to thank the credit union that shared their views on the proposal, which we included in our letter. While our letter pointed out many ways the proposal could be improved, we stressed our overarching concern: “[T]his proposal is directed at the wrong parties. Those who design, program, and sell AVMs should be the targets of the new rules, not credit unions, which have no control over how AVMs are created. AVM vendors know that their products will be used by, and relied upon by, end-user lending institutions. And AVM vendors know that those institutions have obligations to comply with Fair Housing and other nondiscrimination laws. Requiring those institutions to police the internal functioning of AVM systems they did not create is inefficient and misguided.”
Final rule issued
Yes. See this Compliance Courier for information.
CFPB: Credit card late fee limitations
The League’s comments
The League commented on the CFPB’s proposal to cut allowable credit card late payment fees. We pointed out that member-owned credit unions have a built-in disincentive against charging excessive fees, and that the Bureau’s “one-size-fits-all” approach to a late fee cap was misguided and not backed up by solid evidence. We told the CFPB that it “should either exempt credit unions from the scope of this proposal altogether, or it should exempt smaller card issuing depository institutions from the rule’s coverage. In addition, the CFPB should recognize that slashing allowable late fees is likely to have serious consequences for U.S. consumers, including increases in other fees, tighter credit standards, and less access to credit card products.”
Final rule issued
Yes. See this Compliance Courier for information.