This paper is the Credit Union National Association’s (CUNA) comprehensive response to the various requests for information (RFIs) issued by the Bureau of Consumer Financial Protection (Bureau or CFPB) in the spring of 2018.
Credit unions are the original consumer financial protectors. Because of their not-for-profit, cooperative ownership structure, credit unions do not face the same market pressures and they do not have the same structural motives as for-profit financial services providers. This distinction, combined with decades of providing consumer friendly financial services, is the key reason that consumer protection regulation should be tailored so that it is not overly burdensome on credit unions.