Regulatory Compliance
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Small Credit Unions

On Thursday of last week, the 10th to be exact, the CFPB began releasing the first of its long-awaited final rules. You may have heard. The expectation of the arrival of these rules lessened the force of their impact only a little.

Also on the 10th, the NCUA announced a revision to its small credit union rule (IRPS 13-1) which changed the definition of “small” to those credit unions with $50 million or less in assets, rather than $10 million.

Faced with 1300+ pages of new regulations (previous Works post), some credit unions were searching for hope from every available source. Some wondered if this new definition of “small” meant that those under $50 million would not have to comply with the new CFPB regulations. Sadly, the answer to that is no, the new definition offers no escape from the new regulations. In short, the new definition offers relief in these ways:

  • Offers exemptions from NCUA Rules 702, 741, and 791
  • Approximately doubles the number of credit unions with access to the services of the Office of Small Credit Union Initiatives (OSCUI)
  • Promises that, in future rulemaking, the NCUA will consider the impact of its rules on small credit unions

It should be noted that, while the new definition does not provide an escape for a small credit union from its regulatory burden, part of the services offered by the OSCUI include regulatory consulting. Small credit unions would be well-served to understand any benefits they can gain from this new definition.


Final Rule

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