Phillip Matous, president/CEO of the $53 million Total Community Credit Union of Taylor, Mich. has thrown the book – a heavy one – back at his legislators and regulators.
To emphasize how the compliance burden on credit unions has reached a “ridiculous” point, Matous printed copies of the 1,099-page Consumer Financial Protection Bureau request for comment on its proposed combined mortgage disclosure rules and mailed them with his comment letter to U.S. Reps. John Dingell (D-Mich.) and Gary Peters (D-Mich.), U.S. Sens. Debbie Stabenow (D-Mich.) and Carl Levin (D-Mich.), CFPB Director Richard Cordray and NCUA Chairman Debbie Matz.
Printed double-sided, Matous said the request for comment is more than 2 inches thick.
“I hope that by seeing the ponderous size of the enclosed CFPB 1,099-page proposed rule concerning RESPA and Truth in Lending, you can appreciate the damage current regulations are having on our democracy and republic,” Matous wrote in his comment letter, which he also emailed to colleagues and the media.
“This is rule by edict under the guise of democracy. If the regulations overwhelm the regulated,” Matous wrote, “the regulator can easily impose their will on the public. Who can easily digest and comment on such voluminous writing?”
Chair of the Michigan Credit Union League Legislative Issues working group, Matous said he enjoys reading new regulations, but he criticized a recently released interagency 211-page rule that places new restrictions on higher-risk mortgages.
He sourced one paragraph in the rule that cited several cross references, which he said requires nearly 18 years of education to understand, according to the Flesch-Kincaid Grade Level Formula.
That complexity violates the Plain Writing Act of 2010, according to the CEO of the 7,100-member suburban Detroit credit union, and he urged the CFPB and other regulators to comply with the law, as well as an executive order from President Obama mandating the same.
“Such voluminous requests for comments are becoming the norm,” Matous wrote. “They are harming, not aiding consumers, and our democracy. Regulators will not receive the benefit of years of field experience that could enhance the benefits in their proposals.”