Debit interchange proposal, final overdraft rule included in rulemaking agenda

Federal regulators—including the NCUA and CFPB—released their Spring 2024 Unified Agenda of Regulatory and Deregulatory Actions, highlighting potential timelines for upcoming agency actions (but not a definitive schedule with specific timelines).

The Federal Reserve’s agenda indicates “further action” on its debit interchange proposal in January 2025. America’s Credit Unions strongly opposes the proposal—which would adjust all three components of Regulation II’s interchange fee cap—and has called on the Fed to withdraw it.


  • Proposed rule stage, Digital Assets and Related Technologies, January 2025, following a 2021 request for information on issues pertaining to decentralized finance, digital assets, and the use of distributed ledger technology as they relate to the credit union industry. America’s Credit Unions’ legacy organizations submitted comments asking for guidance in this area. 
  • Proposed rule stage, Executive Compensation Transparency, October 2024, to require federal credit unions to provide information on executive compensation to their members, similar to what state-chartered credit unions provide under IRS Form 990. 
  • Proposed rule stage, Appeals Procedures, September 2024, to clarify current regulations regarding the procedures for appealing material supervisory determinations and appeals procedures that do not, by law, require a Board hearing and provide additional requirements and flexibility for credit unions to appeal material supervisory determinations. 
  • Proposed rule stage, Investment and Deposit Activities, September 2024, to modernize and improve the agency’s investment rule. The proposed rule would address provisions that may be unclear or unnecessary from a safety and soundness perspective. America’s Credit Unions and the National Association of Credit Union Service Organizations requested NCUA update this rule to enhance credit union opportunities to invest in fintech. 


  • Proposed rule stage, Financial Data Transparency Act, July 2024, regulators including the CFPB and NCUA are collaborating on a proposed rule to establish unified data standards for information reporting by financial entities to the regulatory agencies, as mandated by the FY23 National Defense Authorization Act.
  • Proposed rule stage, Fair Credit Reporting Act Rulemaking, July 2024, new regulations for consumer credit reporting agencies and reevaluating the inclusion of medical debts in credit reports and lending decisions under the Fair Credit Reporting Act. The CFPB proposed in June to remove a regulatory exception in Regulation V from the limitation in the FCRA on creditors obtaining or using information on medical debts for credit eligibility determinations. America’s Credit Unions’ legacy organizations objected to the rushed rulemaking process and requesting a new outline of proposals.
  • Final rule stage, Overdraft Lending: Very Large Financial Institutions, January 2025, to finalize the January proposal on overdraft services at institutions with more than $10 billion in assets. America’s Credit Unions opposes the proposed rule noting that it would harm essential services, affect institutions of all sizes, and potentially violate legal precedents.
  • Final rule stage, Required Rulemaking on Personal Financial Data Rights, October 2024, to finalize an October 2023 proposed rule to implement section 1033 of the Dodd-Frank Act, introducing standards for consumer financial data portability that will require institutions such as credit unions to develop and maintain APIs for the purpose of enabling permissioned, third party-access to certain categories of member information. America’s Credit Unions’ legacy organizations wrote in strong opposition to the proposal.

Financial Crimes Enforcement Network

  • Proposed rule stage, Revisions to Customer Due Diligence Requirements for Financial Institutions, October 2024, to revise its CDD requirements for financial institutions to account for the changes created by the beneficial ownership information reporting and access requirements set out in the Corporate Transparency Act. America’s Credit Unions supports sensible changes related to the current CDD requirements. 

Cybersecurity and Infrastructure Security Agency

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