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MCUA Comment Letters

CFPB and NCUA Adopt Supplemental Rule on Appraisals for "Higher-Priced Mortgage Loans"

Dec
19

The Consumer Financial Protection Bureau (CFPB), National Credit Union Administration (NCUA), and other federal financial regulators adopted a supplemental rule that amends Reg Z-changes made by a January 2013 final rule* regarding appraisals for “higher-priced mortgage loans” (HPML)— formerly referred to as “higher-risk mortgages.” For certain mortgages with an APR that exceeds the average prime of

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NCUA Issues Final Rule on Charitable Donation Accounts

Dec
17

In its December 12 meeting, the National Credit Union Administration (NCUA) Board adopted a final rule regarding charitable donation accounts (CDA), the creation of which the Missouri Credit Union Association (MCUA) strongly supports.

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MCUA Comment Letter on Charitable Donation Accounts Proposal

Nov
13

The National Credit Union Administration (NCUA) has posted the letters filed for comment on the charitable donation accounts proposed rule, which Credit Union National Association (CUNA), the National Credit Union Foundation (NCUF), and a number of leagues support in principle with a few improvements.

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MCUA Supports Proposed Exemptions from Appraisal Requirements for HPMLs

Sep
09

On Monday, Sept. 9, 2013, the Missouri Credit Union Association (MCUA) filed a comment letter on a joint proposal that would provide additional exemptions from the appraisal requirements for “Higher-Priced Mortgage Loans” (HPMLs) under Regulation Z.

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MCUA Comments on Two FASB Proposals

Aug
27

On Friday, Aug. 23, 2013, the Missouri Credit Union Association (MCUA) filed comment letters on two separate Financial Accounting Standards Board (FASB) proposals, both of which were developed through FASB’s Private Company Council (PCC). MCUA generally supports both proposals as issued for comments. The proposals would allow private reporting entities—including credit unions—to elect alternative standards within U.S.

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MCUA Comments on NACHA's Latest Compliance & Operational Topics Proposal

Apr
08

The Missouri Credit Union Association (MCUA) has filed a comment letter on The Electronic Payments Association's (NACHA) latest compliance and operational topics proposal.

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MCUA Comments on FFIEC Social Media Use Guidance

Mar
25

The Missouri Credit Union Association (MCUA) has submitted a comment letter about social media guidance to the Federal Financial Institutions Examination Council (FFIEC).

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FinCEN CDD Proposal Update; Virtual Currencies Guidance

Mar
25

The U.S. Treasury Financial Crimes Enforcement Network (FinCEN) will likely issue a proposed rule on customer due diligence (CDD) in the “coming weeks,” based on recent comments by senior U.S. Treasury officials.

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MCUA Comments on CFPB Proposal on Ability to Repay

Feb
25

The Consumer Financial Protection Bureau (CFPB) has already adopted a final rule to implement the ability to repay provisions regarding closed-end mortgage loans under the Dodd-Frank Act. The rule takes effect January 10, 2014. However, the agency is also seeking comments, through today, February 25, on a proposal that would allow some creditors to have more flexibility in complying with the rule.

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MCUA Urges Changes to CFPB's TILA-RESPA Rule

Nov
15

On November 6, 2012, the Missouri Credit Union Association (MCUA) filed a comment letter with the Consumer Financial Protection Bureau (CFPB) on the agency’s proposed rule to amend Regulation Z, Truth in Lending Act (TILA), and Regulation X, the Real Estate Se

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