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Noting that "credit unions are not unscrupulous actors" consumers need protection from, NAFCU has identified opportunities for the CFPB to provide credit unions with regulatory relief under its inherited regulations. The bureau's inherited regulations are those rulemaking authorities transferred to the bureau from other federal agencies by the Dodd-Frank Act.

NAFCU Regulatory Affairs Counsel Kaley Schafer sent a letter to the bureau Monday in response to its request for information (RFI) on inherited regulations. Schafer wrote that "inherited regulations were designed to protect consumers from unscrupulous acts by large complex financial institutions." She argued that missed opportunities by the bureau to better tailor regulations or completely exempt credit unions from its rulemakings have "subjected them to a host of unnecessary regulations intended to deter bad actors" and forced many to stop operating because of high compliance costs.

Specifically, in order to reduce credit unions' regulatory burden, Schafer recommended that the bureau:

• maintain the alternative delivery method and increase the notification period for revised annual notices required under the Gramm-Leach-Bliley Act;

• provide clear guidance on when an approved applicant may be provided with their consumer report under the Fair Credit Reporting Act;

• exclude credit unions from debt collection rulemakings under the Fair Debt Collection Practices Act;

• issue guidance on how disaggregated data will be compiled and reported to comply with Regulation C of the Equal Credit Opportunity Act;

• review Appendix A to Part 1008 of the Secure and Fair Enforcement for Mortgage Licensing Act for clarity on the definition of "mortgage originator" and "takes a loan application";

• not curtail credit unions' overdraft programs with a rulemaking under the Electronic Fund Transfer Act;

• change the frequency of required credit card agreement posting to the bureau under the Truth in Lending Act (TILA); and

• provide an exemption from escrow requirements under TILA for high-priced mortgage loans where the borrower does not own the land.

Schafer's letter, with detailed explanations of NAFCU's recommendations, is available here.