← Cooperative Credit Union Association
CFPBRulemakingCFPB-2024-0002

Overdraft Lending: Very Large Financial Institutions

RIN
—
Last modified
Oct 1, 2024
Comment window
closed 848d ago
Cooperative Credit Union Association filings
1

Activity

Cooperative Credit Union Association filed 1 comment on this docket between Apr 1, 2024 and Apr 1, 2024. 75 other organizations filed here. The comment window closed 848d ago.

What Cooperative Credit Union Association filed (1)

Apr 1, 2024· Comment from Cooperative Credit Union Association· CFPB-2024-0002-0678

See attached comments. Below are the highlights from the letter. •The Association does not support the Bureau's proposal to regulate overdraft fees pursuant to the Truth in Lending Act (Regulation Z). While this proposal would only apply to "very large" credit unions (i.e. those with more than $10 billion in assets), the Bureau states that it may expand this approach to apply to all credit unions. This proposal is inappropriate for all credit unions, including "very large" ones, and would disadvantage credit union members. •Credit union members desire access to overdraft protection, which is not underwritten as credit. Under current law, consumers must opt-in to receive overdraft coverage and fees must be clearly disclosed. •The Association does not support the proposal to treat any overdraft fee as a "finance charge" under Regulation Z if it is "above breakeven" based on either the credit union's costs and losses or a benchmark set by the Bureau. If the Bureau does set a benchmark, it should be based on current market averages as well as adjusted for inflation. •We also do not support eliminating the Regulation Z exemption for overdraft fees that do not exceed the non-sufficient funds (NSF) fee the institution would charge it if does not honor an overdraft. Eliminating this exemption would disadvantage consumers since they would face the same or higher out-of-pocket costs without being able to pay their bills on time.

View on regulations.gov →

Abstract

SUMMARY: The Consumer Financial Protection Bureau (CFPB) proposes to amend Regulations E and Z to update regulatory exceptions for overdraft credit provided by very large financial institutions, thereby ensuring that extensions of overdraft credit adhere to consumer protections required of similarly situated products, unless the overdraft fee is a small amount that only recovers applicable costs and losses. The proposal would allow consumers to better comparison shop across credit products and provide substantive protections that apply to other consumer credit. ADDITIONAL INFORMATION: For more information about commenting on CFPB’s Notices, please visit us at: https://www.consumerfinance.gov/rules-policy/notice-opportunities-comment/commenting-on-notices/

View on regulations.gov →

Co-filers (75)

See everyone who commented →