The Government Accountability Office (GAO) released a report, entitled “Agencies’ Efforts to Analyze and Coordinate Their Rules.” The report covers the regulatory analysis federal financial regulators, such as the CFPB and NCUA, performed for rules issued pursuant to the Dodd-Frank Act; how the agencies coordinated with each other on rulemakings; and what is currently known about the impact of these rules. The GAO identified 66 Dodd-Frank final rules that were issued between July 2011 and July 2012, including rules on debit interchange fees, risk-based pricing, and systemically-important financial institutions.
The GAO continues to recommend that regulators more fully incorporate comprehensive cost-benefit analysis into the agencies’ rulemakings, and that the Financial Stability Oversight Council establish formal interagency coordination. Also, the GAO report noted continued concerns from small issuers about the potential for their interchange fee income to decline over the long term. In addition, the GAO found that while the federal agencies considered the benefits and costs in the majority of their rules, the agencies generally did not quantify the costs and impact for such rules. As we carefully monitor the implementation of the Dodd-Frank Act, we continue to have concerns regarding the effects from the debit interchange and other Dodd-Frank rules on credit unions. CUNA continues to urge regulators to reduce regulatory burdens on credit unions and to conduct more rigorous cost-benefit analysis during the rulemaking process.