The following letter was submitted to OIRA by the Credit Union National Association
December 21, 2011
Mr. Cass R. Sunstein
Office of Information and Regulatory Affairs
The Office of Management and Budget
725 17th Street, NW
Washington, DC 20503
Dear Administrator Sunstein:
On behalf of the Credit Union National Association, I am writing to ask you to urge President Obama to issue another Executive Order to Independent Regulatory Agencies, this one calling for a moratorium on new rules that would impose on smaller institutions, such as credit unions, regulatory burdens that are not required by statute or necessitated by serious, material, quantifiable, and well-documented safety and soundness concerns. Regulatory burdens, which are overwhelming yet growing, present very serious concerns to the approximately 7,300 state and federal credit unions in this country. By way of background, CUNA represents about 90% of the nation’s credit unions, which provide financial services to approximately 93 million consumers and small businesses.
Credit unions and CUNA were very pleased that President Obama issued Executive Order 13579 in July urging agencies, such as the National Credit Union Administration, Consumer Financial Protection Bureau, Federal Reserve Board, Federal Trade Commission, and others, to take steps to improve the regulatory environment for the entities under their jurisdiction. We are also pleased that you requested agencies to provide information to OMB on how they are responding to the Executive Order.
These are positive steps. Yet, smaller institutions, such as credit unions, are in great need of meaningful regulatory relief – the kind of relief that they have not seen as of yet.
We are not suggesting that prudential regulators be urged to ignore significant safety and soundness issues or statutory directives. However, the time has come to stop other new regulatory requirements under a moratorium. Such a moratorium would facilitate compliance for agencies with Executive Order 13579 by allowing them to actually take stock of their rules and report to you on not only which provisions have been eliminated but also the impact of the removal of those provisions.
We also urge you to establish an Office of Regulatory Burden Monitoring that would focus exclusively on measuring and scrutinizing the extent of the regulatory burdens that entities, such as credit unions, must shoulder. Such an office could also give regulated entities additional recourse in terms of having their regulatory burdens reviewed.
We urge you to help achieve a regulatory moratorium, and we would welcome the opportunity to discuss this letter with you at your convenience. Thank you for your attention to this most important concern for credit unions.
President & CEO
Credit Union Natl. Assn. (CUNA)