CUNA urges full credit union exemption to ability-to-repay

On June 18, Credit Union National Association (CUNA) witness Jerry Reed detailed credit union concerns with the Consumer Financial Protection Bureau's (CFPB) ability-to-repay and qualified mortgage (QM) rules.  Reed, who is chief lending officer at Alaska USA Federal Credit Union, said credit unions commend the CFPB for listening to their concerns and for incorporating many of their concerns into amendments to the mortgage rules, but he underscored that credit unions continue to have serious apprehensions about how the QM rule will be implemented and believe that it could have the unintended effect of reducing credit union members' access to credit.

"Credit unions were created to promote thrift and provide access to credit for provident purposes to their members. The credit union structure and historical performance of credit union mortgage loan portfolios strongly support a full credit union exemption from the QM rule," Reed said as he testified at the House Financial Services subcommittee on financial institutions and consumer credit hearing on "Examining How the Dodd-Frank Act Hampers Home Ownership."

As not-for-profit, financial cooperatives, Reed reminded, credit unions are owned by the members that they serve. This fundamental difference between the for-profit and not-for-profit sector of the financial services industry provides a significantly different incentive structure for those managing the institutions, Reed noted.

In addition, credit unions are primarily portfolio lenders, typically selling less than a third of their new originations. The fact that most of the loans they make will be held in their own portfolios is further incentive for them to be particularly attentive to the applicant's potential ability to repay.

"While we appreciate the fact that the bureau has provided a modest exemption for small volume originators, we question the need to apply this rule to credit unions in the first place, and urge the Bureau to consider exempting credit unions from the rule entirely," Reed said.

The QM rule is scheduled to go into effect January 2014.