Federal agencies release outline of upcoming rulemaking activity
Analysis of federal regulators’ 2026 Unified Agenda is now available from America’s Credit Unions. The agenda contains potential timelines for actions agencies are considering, but it is not a definitive schedule with specific timelines.
The analysis examines nearly four dozen items on the unified agenda from agencies including NCUA, CFPB, FinCEN, Federal Trade Commission, Federal Reserve, Treasury, Homeland Security, Federal Housing Finance Agency, Department of Housing and Urban Development, and more. It also includes links to the full agenda for each regulator.
Many items on the agenda correspond to priorities America’s Credit Unions has engaged regulators on, including:
Personal financial data rights reconsideration: The CFPB plans to take the appropriate rulemaking steps necessary to reconsider the November 2024 final rule implementing section 1033 of Dodd-Frank.
- America’s Credit Unions has advocated for a revised rule that would afford credit unions more flexibility to charge appropriate member fees and accommodate institutions who offer legitimate secondary uses of covered data.
Revisions to Customer Due Diligence (CDD) requirements: FinCEN intends to issue a proposal to revise its CDD requirements for financial institutions to account for the changes created by the beneficial ownership information (BOI) reporting and access requirements set out in the Corporate Transparency Act
- America's Credit Unions urged FinCEN to issue a CDD proposal in a 2024 letter.
Central Liquidity Facility (CLF): NCUA is considering a proposal to make certain CLF rule changes adopted through interim final rules in 2020 and 2021 permanent while removing provisions that expired.
- America’s Credit Unions has consistently advocated for updates to the CLF regulations, including a June letter urging improvements to the CLF to ensure it continues to function as a timely and accessible source of liquidity for credit unions.
Community bank leverage ratio modifications: The Federal Reserve, jointly with the Office of the Comptroller of the Currency and Federal Deposit Insurance Corporation, expects to invite comment on a proposal that would make adjustments to the community bank leverage ratio. While the rulemaking is not applicable to credit unions, the widely anticipated reduction in the CBLR from 9% to 8% may influence the NCUA’s calibration of its analogous Complex Credit Union Leverage Ratio (CCULR).
- America’s Credit Unions submitted a letter to the NCUA advocating for a reduction in the CCULR to 8% last year.