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MCUL GAC

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.

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MCUL GAC

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  1. MCUL GAC Presented by: John J. Kolhoff, Director Office of Credit Unions NASCUS Board Chair March 25, 2014

  2. 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.

  3. 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.

  4. 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.

  5. 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.

  6. 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

  7. 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.

  8. 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).

  9. NCUA Rules (open comment) • Risk based Capital • NCUA 2014 Rule Review

  10. 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.

  11. 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.

  12. 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.

  13. 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

  14. 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.

  15. 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.

  16. Contact Information John J. Kolhoff, Director kolhoffj@michigan.gov @difsjohnkolhoff Twitter www.michigan.gov/creditunion Phone (517) 373-6930 Fax (517) 335-0908

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