Massachusetts Regulatory Advocacy

Credit unions are subject to state and federal regulations that govern the full range of their operations. In addition to the two primary credit union regulatory bodies, credit unions must be well informed about the regulations promulgated by a wide variety of other governmental organizations. The Association goes far beyond reporting on new initiatives by taking a proactive role in assisting credit unions to work with regulators to build a regulatory environment that will benefit and protect credit unions and their members. Anticipating regulatory change, promoting dialogue between credit unions and regulators, interpreting existing regulation, and acting as an advocate for credit unions in regulatory forums are vital services delivered by the Association.

Massachusetts Division of Banks

 

The Massachusetts Division of Banks provides access to their proposed regulations. Click here to visit their website. This site also contains copies of the Notices of Public Hearings on proposed regulations which indicate the deadlines for comment letters.

Testimony Letter: 209 CMR 40.00 et seq., Unfair and Deceptive Practices in Consumer Transactions 03-22-2016

Application Forms

The Massachusetts Division of Banks provides online application forms for many business activities. Click here to visit their website.

Mass. DOB Industry Letter on Cyber Self Assessment 09-2015

Massachusetts Division of Banks and Loan Agencies: Regulatory Bulletin 2.1-104 Branch Office Notice and Application Procedures 11-18-2015

Massachusetts Parity Regulation Amendments Survey- 209 C.M.R. 50.00 et.seq

In Massachusetts, the process of finalizing a formal request to the Massachusetts Commissioner of Banks for amendments to the state chartered credit union parity regulations found at 209 C.M.R. 50.00 et. seq. is well underway.

The statutory authority governing parity for state chartered credit unions expressly permits the exercise of certain powers granted through regulation by the Division of Banks and Loan Agencies (“Division”) applicable to federal credit unions under the Federal Credit Union Act to the extent that such powers are not otherwise prohibited under Massachusetts law. The expanded powers are intended to promote "competitive equality" between state-chartered credit unions and federally-chartered credit unions. In addition, the parity regulations cover all adequately-capitalized and eligible credit unions regardless of size, so all eligible small- and medium-sized credit unions are able to take full advantage of the expanded authorities.

The general framework of the parity regulations adopted by the Division reflect a risk-based system of supervision. The Association has rigorously advocated that the parity regulations were not intended to be a static listing of federally-chartered credit union powers. The Legislature, the Division and the credit union movement all view the federally-chartered credit union parity process as a continuously evolving one. Consequently, it was intended that additional federally-chartered credit union powers would be adopted on a periodic basis to reflect changes in federal credit union laws, official interpretations, and operating conditions.

Recommendations from member credit unions on specific authorities are of interest, together with any particular problems experienced. Specific citations are not necessary. The Association will review all ideas to determine the most effective and timely solution. A link to the survey is found in the member-only content below and requires user name and password to access.

Proposed Regulation 209 CMR 58:00: Credit Union Branching
Association’s written testimony filed with the Division 
Division of Banks Statement in Support of 209 CMR 58.00
Association NH Statement
Association RI Statement
Connecticut Community Reinvestment Act
RI Department of Business Regulation CRA Decision
NCUA Opinion Letter

Testimony offered at the June 17, 2015 hearing by:
Carl Taber, Executive Vice President/Senior Lending Officer at Baycoast Bank
Jon Skarin, Senior Vice President of the Massachusetts Bankers Association
Tom Callahan, Executive Director of the Massachusetts Affordable Housing Alliance 

Comment Letter in support of House 3590, An Act Relative to Notifying Automobile Lien Holders of Certain Towing and Storage Costs 092315

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