Comments and feedback on the CFPB’s proposal on instantly declined transactions will help America’s Credit Unions shape the discussion and address credit union needs. The latest Regulatory Comment on the proposal was issued Monday with a summary, list of questions for credit unions to consider, and more.
The proposal would prohibit financial institutions from charging fees—such as nonsufficient funds (NSF) fees—when consumer transactions are instantaneously declined.
While charging these types of fees is very rare and the proposal is expected to have minimal impact on credit unions, changes to fees structures, policies, and internal systems would be necessary for those covered by the rule.
America’s Credit Unions is concerned with the proposal’s expansive interpretation of the CFPB’s unfair deceptive, or abusive acts or practices (UDAAP) authority. Such expansion could create uncertainty for credit unions and have significant implications on a wide variety of products and services.
Comments are due to America’s Credit Unions March 11, and to the CFPB March 25.
Additional analysis of the proposal can be found on America’s Credit Unions’ Compliance Blog.