The presidents of all of the Federal Home Loan Banks have written to the National Credit Union Administration (NCUA) in support of the use of the FHLBanks as a source of emergency liquidity for credit unions. In July 2012, NCUA issued a proposal that addresses emergency liquidity requirements for federally insured credit unions. The proposal would require credit unions with assets of $100 million or more to have access to a backup federal liquidity source for emergencies. The proposal limited credits unions’ choices to the Central Liquidity Facility or the Federal Reserve’s Discount Window.
In the Credit Union National Association's (CUNA) comment letter and in subsequent meetings and communications with NCUA, they have urged that the agency allow the FHLBanks to serve as a source of emergency liquidity for FHLBank member credit unions, as well as the CLF and the Discount Window. CUNA has also urged that the agency should work with the FHLBanks to develop the memorandum.
CUNA Survey Seeks Input on Effectiveness of CARD Act
CUNA is encouraging credit unions to participate in a survey they are conducting in regard to the effectiveness of the Credit Card Accountability Responsibility and Disclosure Act (CARD Act). CUNA will use data collected through the survey along with comments received through their Comment Call to develop CUNA’s comment letter to the Consumer Financial Protection Bureau (CFPB), which is accepting comment until February 19. As required by the CARD Act, the CFPB is in the process of gathering information on several aspects of the consumer credit card market.
The CARD Act changed the requirements applicable to credit card pricing in a number of significant respects. Prior to the CARD Act, the applicable provisions of the Truth in Lending Act (TILA) and its implementing regulation (Reg Z) focused principally on how companies needed to disclose product pricing terms to consumers, and otherwise placed few substantive limits on industry practice. However, after the CARD Act, TILA and Reg Z also imposed direct limits on a number of pricing practices that Congress deemed unfair or unclear to consumers.
CUNA’s survey seeks input on changes to the credit card market as a result of the CARD Act, including any impact on the cost and availability of credit to borrowers. All data submitted in connection with the survey will be aggregated and will not be associated with any credit union in particular.
Completion of the survey is requested by February 8.