8 FOCUSREPORT/2021 Regulatory OutlookThe credit union advo- cacy goal – to revo- lutionize the operat- ing environment forcredit unions through the removal of regulatory burdens andthe expansion of powers andopportunities – is intentional.Those words are at the center ofCUNA’s strategic plan, and, together with our league partnersand member credit unions, weexecute a strategy to achieve thatgoal.
These efforts have producedmany victories over the lastseveral years. Together, we’veremoved obstacles to memberbusiness lending, expanded fieldof membership opportunities,reduced regulatory burden associated with new risk-based capital regulation, blocked new arbitration regulation, and tailoredmortgage lending, remittancesand small dollar loan regulation,among other big victories.
During the pandemic, we have
worked to make sure policy pro-
moted credit unions’ ability to
be there for their members. Our
advocacy led to credit unions
lending through the Paycheck
Protection Program,
Congress conveying
new liquidity and
troubled debt re-
structuring protec-
tions and the NCUA
transitioning to vir-
tual examinations
and suspending new
rulemaking.
We were able toachieve all of thisbecause we havea strong advocacygoal, a strategy thatworks, and an agenda that is credit unions’ agenda.
The advocacy challenge aheadis maintaining our progress andtaking advantage of opportunities in a fundamentally differentpolitical environment.
Unified Democratic control ofthe federal government, duringa period of political divisivenessunmatched in more than 160years, presents us – and franklyother interest groups – with significant advocacy risk.
What We Are Facing
The economic consequences of
the pandemic will have a longer
tail than the public
health crisis. That is
why we continue to
press for policy that
accommodates pan-
demic-induced fluc-
tuations in net worth
and asset size and
keeps credit unions
in a position to meet
their members’
needs.
As Congress re-
turns to normal
legislative activity,
This credit reporting effort is
undertaken within a broad dis-
cussion on financial inclusion
and economic equity. In this dis-
cussion, we also expect to hear
policymakers push proposals
for a postal or public banking
option. Frankly, these propos-
als are misguided because credit
unions are well-positioned –
though encumbered by archaic
field-of-membership restric-
tions – to help solve the finan-
cial inclusion problem. This is
an opportunity for credit unions
to align our desire to serve more
Americans with policymakers’
push for financial inclusion.
At the NCUA, the new chair-
man will attempt to turn the
agency in a different direction.
Here, the primary risk is that
the agency will respond to the
pandemic-caused instability by
driving the NCUSIF normal op-
erating level significantly higher
than Congress has indicated it
should be. Further, the chair-
man has indicated his desire to
redirect the agency’s critical re-
sources, which are provided by
credit unions, to redundant ex-
amination activities that will not
enhance consumer protection.
In short, it appears the chairman would like to use a broadsword where a scalpel is needed.
Nowhere will our challengesbe as great as they will be atthe CFPB. A new director is expected to undertake the processof undoing the positive work ofthe last several years. What isabout to happen at the CFPB willbe the clearest example of whya bipartisan commission at thebureau is significantly prefer-rable to an omnipotent leader.
Expect the bureau to revisitrecently finalized rules. If it wastouched by the last administration, it appears to be fair gamefor the current. Even more concerning, the bureau will likelyresume the questionable practice of regulation through enforcement, putting practicestraditionally considered compliant in jeopardy outside the legalrulemaking process.
Credit unions exist to improvetheir members’ financial well-being and advance the communities they serve. To prevent misguided policies from impedingthat critical work, all of us – creditunions, leagues and CUNA – mustcontinue to deliver the outstanding 360-degree advocacy that is ahallmark of our movement.
When we work together, wehave a positive impact on policy.Telling our story and showingour work will help us confrontand overcome these dauntingchallenges. And after a whirlwind 2020, we have a lot ofstories to tell. n
GUEST OPINION
The Advocacy Challenge Ahead
Ryan Donovan
Chief Advocacy
Officer
CUNA
Washington, D.C. ‘That is why we
continue to press
for policy that
accommodates
pandemic-induced
fluctuations in net worth
and asset size and
keeps credit unions in
a position to meet their
members’ needs.’
‘… it appears the
chairman would like
to use a broad sword
where a scalpel is
needed.’
