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NAFCU and the CFPB's Office of Innovation Wednesday discussed the bureau's new policies intended to promote innovation and facilitate compliance at financial institutions. Prior to finalizing the policies, the bureau took into account NAFCU's recommendation that participation in innovation programs should be made easier.

NAFCU Director of Regulatory Affairs Ann Kossachev, Senior Counsel for Research and Policy Andrew Morris, and Senior Regulatory Compliance Counsel Jennifer Aguilar participated in the discussion.

NAFCU and the CFPB specifically discussed the Trial Disclosure Program (TDP) Policy and Compliance Assistance Sandbox (CAS) Policy. The TDP allows companies to obtain a safe harbor for testing for a limited period of time disclosures that improve upon existing disclosures, while the CAS Policy provides equivalent protection through resolution of legal uncertainties.

The innovation discussion coincided with the CFPB's Credit Union Advisory Council (CUAC) meeting, during which members discussed the bureau's:

Implementation and guidance: The bureau shared with CUAC its approach, including its process for releasing FAQs, interpretive rules, and informative guidance.

• Regulatory agenda: The bureau indicated movement in the next year on implementing a section of S. 2155 related to high-priced mortgages and low escrow, small business data collection (which the bureau is set to hold a symposium on next month), Property Assessed Clean Energy (PACE) financing, and remittances. Further down the line, the bureau plans to hold a symposium on consumer access to financial records; action on unfair, deceptive, and abusive acts and practices; and a review of its inherited regulations.
• Home Mortgage Disclosure Act (HMDA): CFPB Director Kathy Kraninger participated in the discussion with CUAC focused on the bureau's two proposals related to the act: one to address data collection and reporting requirements, and another to raise its transactional and institutional reporting thresholds.

Today, CUAC will meet jointly with the CFPB's other advisory councils. On the agenda are the bureau's new innovation policies, its NAFCU-supported initiative to help consumers save, and the consumer complaint database.