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As credit unions prepare for the regulatory and legal challenges they will have to confront over the next year, it is striking how dominant a player the CFPB has become in the regulatory scheme of things. At least in the old days, when its primary purpose was implementing Dodd-Frank's mandates, it followed the traditional regulatory process of proposing amendments, getting feedback on those amendments, rejecting comments with which it disagreed, and then giving time to financial institutions to implement these changes. In contrast, the past year has been marked by aggressive use of UDAAP powers, most notably when it comes to overdraft practices. Consequently, when I look at the biggest issues with which financial institutions will have to deal in the coming year, it is not surprising that the most important of them addresses the issue of how much power the Bureau and other regulators have and how they can exercise this power. With that somewhat long-winded lead-in, here is my second annual top 10 list of the trends that will most impact your credit union in the coming year.
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