MCUL & Affiliates is seeking comments from credit unions on three separate topics.
The first is regarding an NCUA proposal to amend their regulation to require all federally insured credit unions to submit call reports and other data to update their credit union profiles electronically using NCUA’s information management system or other electronic means specified by the NCUA. Since filing manually will no longer be an option, the MCUL is interested in feedback from credit unions to determine if this proposed requirement would result in undue hardship for small credit unions. The request for comment can be found here and comments are due on Sept. 3.
The second request for comment is regarding a proposed rule issued jointly by the agencies (CFPB, FRB, FDIC, FHFA, NCUA and OCC) that would create additional exemptions to the appraisal requirements for extensions of credit for higher-priced mortgage loans under the Truth in Lending Act. The Agencies are seeking a significant amount of feedback on their proposed rule and the MCUL is seeking information from credit unions in response to those questions in order to craft a letter representative of their comments, approval and/or concerns. The request for comment can be found here and comments are due on Sept. 9.
Lastly, MCUL is also seeking comments on a proposal from FASB to revise the definition of a “public business entity” within the Master Glossary of the FASB Accounting Standards Codification ®. This proposed definition would exclude not-for-profit entities and certain employee benefit plans. The request for comment can be found here. Comments for this proposal are due on Sept. 20.