Presented by:John J. Kolhoff, DirectorOffice of Credit UnionsNASCUS Board Chair

March 25, 2014

NASCUS representation on the federal level State regulator representative on the State

Liaison Committee of FFIEC. Represented on several task forces of the

FFIEC including Consumer Compliance and Information Sharing.

Participating member of Federal Banking and Information Infrastructure Committee (FBIIC).

Participating member of the State Coordinating Committee relative to the CFPB.

Strong working and coordinating relationship with other regulatory associations including; CSBS, NAIC, AARMM, NCSL.

Strong working and coordinating relationship with trade associations including; CUNA, AACUL, individual leagues, NACUSO and others.

Educational and Accreditation initiatives.

Monitoring and advancing the regulatory interests of state regulators and state-chartered credit unions.

Closely monitors individual state and federal regulatory issues.

NASCUS advocates in the establishment of a five person NCUA Board. One Board seat should be a former state regulator.

Derivatives Significant impact on the final NCUA Rule

which applies almost exclusively to FCUs. FISCUs must notify NCUA prior to entering

into the derivatives market. State regulations apply. Working with MCUL on opinion regarding

implied authority for MI CUs to have this authority.

IRR Significant regulator concern regarding

potential IRR in depositories in general. OCU to implement the FFIEC “S” or

Sensitivity to Market Risk Component. Letter to be issued soon.

BSA Compliance OCU working with NASCUS and CUNA to

bring the BSA School to Michigan. CyberSecurity

Significant work on NCUA, FFIEC, FBIIC and other regulator task forces.

Seeking useful guidance relating to depository responsibility relating to marijuana related business services.

Internal housekeeping initiatives.

Stress Testing and Capital Planning Home Based FCU Rules (applies to FCUs) Incentive Based Compensation (held up

due to federal interagency issues).

Risk based Capital NCUA 2014 Rule Review

Flood Insurance - H.R. 3370 Passed both Houses Sent to President 3/18/14 Limits annual premium increases to an

average of 15%/year or individually to 18%.

Goal of no premium more than 1% of the value of the total coverage.

Grandfathers comes that complied with previous flood maps.

CFPB Reform – H.R. 3193 Passed House with R support. Renames Financial Product Safety

Commission. Creates a five person commission. Subjects agency to annual appropriations

process. Requires agency to obtain consumers’

permission before examining personal financial data.

Easier avenues for FSOC to delay or set aside agency’s regulations.

Regulatory Transparency – H.R. 2804 Passed House with R support Requires each federal agency to submit a

monthly report to Office of Management and Budget for each rule the agency expects to finalize during the following year.

CU Residential Loan Parity Act – H. R. 4226

Introduced in the House on 3/13/14 Referred to Financial Services Committee Amends the FCUA to exclude a loan

secured by a non-owner occupied 1-4 family dwelling from the definition of a MBL

Supplemental Capital – H. R. 719 49 co-sponsors in the House Actively pursuing introduction in the

Senate Participated in meetings with several

legislative representatives including staff of the Banking Committees.

Fully support the broader availability of this authority already allowed for LIDCU.

Access to FHLB system for all CUs – H.R. 3584

Passed out of the House Fin. Services Committing.

Awaiting floor vote. References to NCUA receiving audit and

exam materials for private insurer removed.

Contains provision requiring SSAs to certify CU’s eligibility for federal insurance.

John J. Kolhoff, Directorkolhoffj@michigan.gov

@difsjohnkolhoff Twitterwww.michigan.gov/creditunion

Phone (517) 373-6930Fax (517) 335-0908