This question has been asked of me numerous times over the past few weeks. Some impacts are known, some impacts are unknown, and unfortunately even some questions are not even known (yet).
What we do know is that credit unions will need to start planning now for some of the known upcoming changes resulting from the Act such as new appraisal requirements for “high risk mortgages,” reporting of executive compensation to the NCUA (for credit unions with assets over $1 Billion), and new rules for debit card interchange fees.
Credit unions can also start thinking about some of the upcoming unknown changes. Basically these would be the changes that are required by the Act, but as of yet, we don’t fully know or understand how they will be implemented. Examples of these changes include the requirement of lenders to ensure the borrower’s ability to repay, expanding protections for high-cost mortgage loans, and additional disclosures for variable rate mortgages.
Based on what we do and don’t know, credit unions can get a head start on planning for the future. The problem is, however, we don’t know what we don’t know! Meaning, we don’t know what the Consumer Financial Protection Bureau (CFPB) has in store for us beyond what is explicitly detailed in the Act. The CFPB will have the ability to autonomously write rules for consumer protections governing all financial institutions, including credit unions. Does this mean the CFPB will rewrite Regulations B or Z? No one really knows.
Not knowing what you don’t know can be very frightening! The best course of action is to remain calm, plan for what you do know, and keep your eyes wide open for what you don’t know…as you never know when it might sneak up behind you! It is the month for ghosts and goblins.