MCUL GAC Presented by: John J. Kolhoff, Director Office of Credit Unions NASCUS Board Chair March 25, 2014
Federal Representation • NASCUS representation on the federal level • State regulator representative on the State Liaison Committee of FFIEC. • Represented on several task forces of the FFIEC including Consumer Compliance and Information Sharing. • Participating member of Federal Banking and Information Infrastructure Committee (FBIIC). • Participating member of the State Coordinating Committee relative to the CFPB.
State Coordination • Strong working and coordinating relationship with other regulatory associations including; CSBS, NAIC, AARMM, NCSL. • Strong working and coordinating relationship with trade associations including; CUNA, AACUL, individual leagues, NACUSO and others. • Educational and Accreditation initiatives.
State Advocacy • Monitoring and advancing the regulatory interests of state regulators and state-chartered credit unions. • Closely monitors individual state and federal regulatory issues. • NASCUS advocates in the establishment of a five person NCUA Board. One Board seat should be a former state regulator.
Recent State Advocacy Successes • Derivatives • Significant impact on the final NCUA Rule which applies almost exclusively to FCUs. • FISCUs must notify NCUA prior to entering into the derivatives market. • State regulations apply. • Working with MCUL on opinion regarding implied authority for MI CUs to have this authority.
Michigan Initiatives • IRR • Significant regulator concern regarding potential IRR in depositories in general. • OCU to implement the FFIEC “S” or Sensitivity to Market Risk Component. Letter to be issued soon. • BSA Compliance • OCU working with NASCUS and CUNA to bring the BSA School to Michigan. • CyberSecurity
Michigan Initiatives • Significant work on NCUA, FFIEC, FBIIC and other regulator task forces. • Seeking useful guidance relating to depository responsibility relating to marijuana related business services. • Internal housekeeping initiatives.
NCUA Rules (comment closed) • Stress Testing and Capital Planning • Home Based FCU Rules (applies to FCUs) • Incentive Based Compensation (held up due to federal interagency issues).
NCUA Rules (open comment) • Risk based Capital • NCUA 2014 Rule Review
Federal Advocacy • Flood Insurance - H.R. 3370 • Passed both Houses • Sent to President 3/18/14 • Limits annual premium increases to an average of 15%/year or individually to 18%. • Goal of no premium more than 1% of the value of the total coverage. • Grandfathers comes that complied with previous flood maps.
Federal Advocacy • CFPB Reform – H.R. 3193 • Passed House with R support. • Renames Financial Product Safety Commission. • Creates a five person commission. • Subjects agency to annual appropriations process. • Requires agency to obtain consumers’ permission before examining personal financial data. • Easier avenues for FSOC to delay or set aside agency’s regulations.
Federal Advocacy • Regulatory Transparency – H.R. 2804 • Passed House with R support • Requires each federal agency to submit a monthly report to Office of Management and Budget for each rule the agency expects to finalize during the following year.
Federal Advocacy • CU Residential Loan Parity Act – H. R. 4226 • Introduced in the House on 3/13/14 • Referred to Financial Services Committee • Amends the FCUA to exclude a loan secured by a non-owner occupied 1-4 family dwelling from the definition of a MBL
Federal Advocacy • Supplemental Capital – H. R. 719 • 49 co-sponsors in the House • Actively pursuing introduction in the Senate • Participated in meetings with several legislative representatives including staff of the Banking Committees. • Fully support the broader availability of this authority already allowed for LIDCU.
Federal Advocacy • Access to FHLB system for all CUs – H.R. 3584 • Passed out of the House Fin. Services Committing. • Awaiting floor vote. • References to NCUA receiving audit and exam materials for private insurer removed. • Contains provision requiring SSAs to certify CU’s eligibility for federal insurance.
Contact Information John J. Kolhoff, Director email@example.com @difsjohnkolhoff Twitter www.michigan.gov/creditunion Phone (517) 373-6930 Fax (517) 335-0908