Today, the Defense Credit Union Council, DCUC, provided formal comments to the Consumer Financial Protection Bureau (CFPB) regarding the agency’s proposed amendments to the Equal Credit Opportunity Act (ECOA) and its implementing Regulation B.
In the letter, DCUC expressed general support for the CFPB’s efforts to clarify regulatory requirements and reduce compliance uncertainty.
The letter highlights key areas of support, including:
Disparate Impact Claims: DCUC agrees with the CFPB’s proposal to align Regulation B with the ECOA’s statutory language, which does not authorize disparate impact claims. This change is expected to provide greater regulatory clarity and more consistent enforcement, while continuing to protect consumers from discrimination.
Discouragement Provisions: DCUC supports revisions clarifying what constitutes prohibited discouragement of credit applicants. DCUC urges the CFPB to retain language that encourages lenders to actively reach out to underserved groups, an important practice for credit unions serving military communities.
Special Purpose Credit Programs: DCUC welcomes regulatory updates aimed at preventing discriminatory use of special purpose credit programs by for-profit organizations, but stresses that credit unions must maintain flexibility to partner with community organizations to expand access to credit.
“Credit unions are deeply committed to fair and inclusive lending, particularly in support of our military members and their families,” reminds Jason Stverak, DCUC Chief Advocacy Officer.
“We appreciate the CFPB’s efforts to streamline regulatory requirements and provide clear guidance that allows credit unions to innovate and serve their members effectively.”
DCUC looks forward to continued collaboration with the CFPB as these proposals move forward.
Additionally, the Defense Credit Union Council, DCUC, sent formal comments to the Consumer Financial Protection Bureau (CFPB) regarding the agency’s proposed revisions to the Small Business Lending Rule under the Equal Credit Opportunity Act (ECOA), specifically Section 1071 of the Dodd-Frank Act.
DCUC expressed support for the CFPB’s efforts to streamline the rule, reduce complexity for lenders, and improve data quality. DCUC also reiterated its longstanding position that credit unions should be exempt from Section 1071 reporting requirements due to their unique lending models and member business lending caps, which limit the usefulness of such data and impose unnecessary regulatory burdens.
Key points in DCUC’s comments include:
Support for Narrowed Scope: DCUC supports the CFPB’s move to narrow the rule’s scope, focusing data collection on core lending products such as loans, lines of credit, and credit cards, while excluding merchant cash advances, agricultural lending, and small-dollar loans under $1,000. DCUC recommends further expanding the small-dollar loan exemption to $5,000.
Increased Coverage Threshold: DCUC backs raising the covered transaction threshold from 100 to 1,000, and recommends raising it further to 2,000 to better protect smaller lenders and credit unions from undue burden.
Reduction of Data Collection: DCUC strongly supports limiting data collection to only those data points expressly required by Section 1071, urging the removal of discretionary data points that add complexity without significant benefit.
Extended Compliance Timeline: DCUC endorses the CFPB’s proposal to establish a uniform compliance date of January 1, 2028, allowing financial institutions adequate time to prepare for the rule’s implementation.
“Credit unions play a critical role in serving military communities, and regulatory requirements must reflect their unique structure and capabilities,” says Jason Stverak, DCUC Chief Advocacy Officer. “We appreciate the CFPB’s efforts to reconsider and refine Section 1071 regulations, and we urge the agency to exempt credit unions or, at minimum, adopt changes that reduce unnecessary burdens while preserving the rule’s intent.”
DCUC remains committed to working with the CFPB to ensure regulatory frameworks support credit unions’ ability to serve their members effectively.