CUNA Comment Letter

Executive Order On Improving Regulation and Regulatory Review

January 20, 2011

The President of the United States of America
The White House
1600 Pennsylvania Avenue, NW
Washington, DC 20550

RE: Executive Order On Improving Regulation and Regulatory Review

Dear President Obama:

On behalf of the Credit Union National Association, I want to express our strongest support for your "Executive Order On Improving Regulation and Regulatory Review." Your order applies to executive branch agencies and would not include independent agencies. However, because of the severe impact of regulations on businesses and our economy regardless of their source, I urge your Administration to look for ways, consistent with separation of powers, to encourage all independent agencies to consider the principals and basic approach to regulation that are so clearly addressed in your order. We are urging the National Credit Union Administration to ensure its policies and regulations are consistent with your order.

As studies from the U. S. Treasury and others have well documented, credit unions are among the most heavily regulated business entities in this country. At the very time when a number of credit unions are having to operate with reduced resources due to the economic crisis that they did not create, they are being subjected to an ever-increasing regulatory load. Because credit unions are financial cooperatives, their members are also burdened, since the costs of meeting regulatory demands are ultimately borne by a credit union's membership.

The need for regulatory reform is critical for financial institutions, particularly in light of many new requirements under the Dodd-Frank Act and continual regulations from the federal financial regulators. One of the key directives of the executive order is for agencies to consider the cumulative impact of regulations. This is positive, but most regulators will focus on their own rules. We urge review of the cumulative impact of all regulations on entities such as credit unions that must operate under rules, directives, guidelines, and orders issued by several agencies. In the case of financial institutions, such a cumulative review would be a welcome role for the Consumer Financial Protection Bureau. We have already been encouraged by comments from your Special Advisor Elizabeth Warren that the CFPB should seek to contain regulatory burdens and costs for institutions that serve consumers and small businesses well, such as credit unions.

Key Members of Congress, regardless of party, have recently called for the regulatory process to be improved. We urge the Administration to work closely with leaders in Congress, whether they are democrats, republicans, or independents, to reduce regulatory burdens in a meaningful way, without jeopardizing key consumer protections or important safeguards. Our economy and our nation will benefit.

Again, credit unions welcome your efforts to pursue regulatory reform.

Sincerely,

Bill Cheney
President and CEO