Limited, targeted questions, as well as efficient information collection methods, should be used to minimize burdens and costs on credit unions when the Consumer Financial Protection Bureau collects information about compliance costs, CUNA has written to the agency.
In a comment letter to the CFPB released Wednesday, CUNA Regulatory Counsel Dennis Tsang said CFPB should fully understand and minimize the potential implementation and ongoing compliance costs and unintended consequences on credit unions from its potential new regulations.
However, he pointed out that the process the agency has delineated for collecting the information may be more burdensome on credit unions, particularly smaller ones.
“While the CFPB estimates that responding to the proposed information collection requests may take up to 90 minutes per response, we believe respondents will have to spend much more time to understand and research the potential regulatory changes and the numerous areas that may be affected at their institution and at third parties they may use, as well as coordinating a response to agency,” he wrote.
“To minimize costs for respondents, the CFPB should develop limited, targeted questions, and provide additional resources to assist respondents with this information collection,” the letter said.
Tsang also suggested that sampling institutions that are representative of the markets affected by the CFPB rulemakings can be more efficient than broader inquiries.
“The agency should utilize proper statistical and research methods to ensure a representative sample for each affected market to properly measure compliance costs,” Tsang wrote. “Other institutions that are not part of the sample should have an option to submit their information after reviewing the information collection materials.”
The CUNA attorney also urged the CFPB to consider the high potential compliance costs and other effects on credit unions, especially smaller credit unions, with regard to the agency’s proposed mortgage, remittance transfer and other regulations.