John Zasada, Compliance Consulting Director, Financial Institutions Group

On May 19, 2021, National Credit Union Administration (NCUA) Chairperson Todd Harper testified before the U.S. House of Representatives’ Committee on Financial Services. Harper’s written testimony touched on a number of important issues, including consumer financial protection. Among his remarks on this subject (emphasis added) was the below:

Specifically, the agency is developing a proposal to enhance consumer compliance examination procedures for the largest credit unions that are not primarily examined for consumer financial protection by the Consumer Financial Protection Bureau (CFPB), performing targeted consumer compliance examination procedures in every federal credit union exam, and developing consumer compliance training materials for examiners and credit unions. The agency is also placing an increased emphasis on fair lending compliance.”

Consequently, credit unions above a certain threshold, but smaller than $10 billion in assets could receive a more thorough and in-depth compliance examination from NCUA examiners in the future, should this upcoming proposal be made final.

If you have questions about how this could impact your compliance program, contact Doeren Mayhew’s regulatory compliance team.