The CFPB has issued a series of filings seeking to reinstate multiple long-standing regulatory information-collection requirements, a move that preserved several compliance obligations that directly affect credit unions. The requests, scheduled to be published Dec. 9 in the Federal Register, would renew Office of Management and Budget approvals for five separate rules governing privacy disclosures, mortgage-advertising standards, land-sales fraud protections, uninsured-depository notices and consumer-reporting safeguards for human-trafficking survivors.
For credit unions, the most widely felt requirement is the Gramm-Leach-Bliley Act privacy rule (Regulation P), which mandates initial and annual privacy notices and opt-out disclosures for data sharing with third parties. The CFPB estimated more than 462,000 institutions fall under the rule, including nearly all credit unions, with a combined compliance burden exceeding 300,000 hours annually.
The Bureau is also moving to reinstate Regulation N, which requires lenders to retain mortgage-advertising materials for 24 months and avoid misleading claims about rates or loan terms. Credit unions offering mortgage products must continue maintaining documentation to demonstrate compliance in the event of supervisory review.
Another reinstatement affects credit unions that accept deposits without federal insurance, a limited but notable subset of military-affiliated and private-share insurers. Regulation I requires these institutions to disclose clearly that accounts are not federally insured, obtain written acknowledgments from members, and display required notices in marketing and account materials.
While most credit unions are not involved in large-scale land-development schemes, the Interstate Land Sales Act reinstatement reaffirmed existing requirements for any credit-union-owned CUSO engaged in real-estate development.
The largest burden estimate, more than 6.2 million hours, came from reinstating Regulation V protections for human-trafficking survivors, which require furnishers and credit unions that report data to credit bureaus to properly flag and block adverse information tied to trafficking.
The filings collectively signaled that, despite broader uncertainty about the CFPB’s future, the Bureau is working to preserve foundational consumer-protection requirements that credit unions must continue to follow.
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