Tuesday, December 07, 2010 10:47:55 AM
WASHINGTON - Under the recent legislation of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), the Bureau of Consumer Financial Protection (CFPB) is provided very broad rulemaking authority and with that comes the power to transfer certain regulations under the CFPB authority.
The Bureau of Consumer Financial Protection (CFPB) under the recent legislation of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) provides the CFPB with very broad rulemaking authority and with that comes the power to transfer certain regulations under the CFPB authority. The CFPB has representatives from all financial institution regulatory agencies. Chairman Debbie Matz represents NCUA on the CFPB board.
Generally, credit unions under $10 billion dollars in assets do not come under CFPB rule, however, the CFPB is an independent body established within and funded by proceeds from the Federal Reserve System, which will be responsible for eighteen major laws that are set to transfer to the CFPB scheduled for between 6 and 12 months after the July 21, 2010 enactment date of the new law and may be extended until 18 months after enactment. CUNA has compiled two charts that document the 'Rulemaking Dates' and the 'Effective Dates' of the changes.
Unless otherwise noted in the statute, credit unions and others are subject to statutory provisions as of the effective date of those provisions, even if the rules have not yet been issued. In those instances, good faith efforts to comply will be important should a credit union's compliance with a particular provision be challenged. Also, as with other comprehensive statutes, the agencies often miss regulatory rulemaking deadlines, so it is up to credit unions to stay abreast of upcoming effective dates.
Below, find important resources on the Dodd-Frank Act and the CFPB.
CUNA Short Summary of Dodd-Frank Act with list of eighteen transferred laws:
CUNA's Dodd-Frank Act Q&A:
Effective Dates Chart for transfer of rules under Dodd-Frank Act applicable to CUs:
Rulemaking Dates Chart for transfer of rules under Dodd-Frank Act applicable to CUs: http://www.cuna.org/reg_advocacy/member/download/Dodd-Frank_Act_chart.pdf