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
– 2025 –
NCUA: Prohibition on use of reputation risk
The League recently filed a comment letter with the NCUA, expressing our support for their proposal to eliminate reputation risk from their supervisory program. As explained in this Compliance Courier, we told the NCUA that “[E]xaminers have had too much latitude to rely on ambiguous and entirely subjective concerns about reputation risk, based on nothing more than the personal preferences of examiners, without grounding their findings in measurable metrics or law.” Our letter quoted (anonymously) the comments sent to us by two credit unions. The League will let you know about further developments on this proposal.
CFPB: Small business lending rule
On Dec. 15, The League submitted a comment letter to the CFPB, expressing our support for a proposal to revise the Bureau’s small business lending data collection rule. As explained in The League’s ii Release No. B083, the rule requires financial institutions that do a certain amount of lending to small businesses to collect and report data about those loans. The League told the CFPB that Wisconsin credit unions strongly back the Bureau’s plan to streamline this rule. Our letter focused on raising the threshold at which financial institutions (including credit unions) would be subject to the rule. For details, please see this Compliance Courier.
CFPB: Personal financial data rights reconsideration
The League has filed a comment letter with the CFPB on Oct. 20, 2025, urging it to revise several key areas of its “open banking” rule. That rule, finalized about a year ago, is designed to give consumers control over their financial data by requiring banks, credit unions, and certain fintechs to share account information (like transaction history and account balances) with authorized third parties if consumers consent. We stressed concerns over information security, fraud, privacy, and the need to charge reasonable fees for this service. We want to thank Summit Credit Union for sharing its views on open banking and its impacts.