MICHIGAN CREDIT UNION LEAGUE

Lapses by the retail industry/merchants in securing consumer information continue to be extremely problematic and costly to consumers and financial institutions. MCUL is advocating that Congress hold retailers to the same or similar data security standard as the financial service industry has to abide by and require that retailers notify credit unions sooner once a breach occurs. We support the introduction and passage of legislation that ensures all businesses, institutions and organizations that collect, collect, use or share personal data subject to national standards, to include language that preempts state requirements, among other things. Credit Unions are fighting a significant surge in fraud/scams that is costing American consumers billions annually. MCUL is educating lawmakers on the impact fraud is having on members and on credit unions. Credit unions are supporting three fraud related bills currently: H.R. 9331, the Strengthening Transaction Oversight and Preventing (STOP) Payments Fraud Act; S.2019/H.R. 4936, the Task Force for Recognizing and Averting Payment Scams (TRAPS) Act; and S.3774/H.R. 7548, the Safeguarding Consumers from Advertizing Misconduct (SCAM) Act. We are urging our delegation to support the legislation and call on leadership to pass the bills. MCUL supports modernizing the Federal Credit Union Act (FCUA). The financial service industry is rapidly changing. Advancements in technology, including high speed internet connectivity, have significantly changed our society and how financial institutions do business. Updating the FCUA has become necessary to ensure federally chartered credit unions have the powers and flexibility to be competitive and members can benefit from new technology. We are currently supporting the Veterans Member Business Loan Act (S.210/H.R. 507) that would exempt credit union business loans to veterans from the member business lending cap and we are supporting the Credit Union Board Modernization Act (S.522/H.R. 975) which would afford federal credit unions flexibility with regard to how often their boards meet. MCUL is monitoring developments for GSE/housing finance reform and will advocate to make sure any reforms reflect the significant role credit unions play in the secondary mortgage market and we will defend against anything that is potentially harmful to credit unions and their members. MCUL is calling on Congress to pass bank secrecy act/anti-money laundering reforms and provide financial institutions relief from unnecessary, duplicate and burdensome rules and increase the SAR and CTR thresholds. MCUL is urging lawmakers in the House to co-sponsor and support H.R. 1799, the Financial Reporting Threshold Modernization Act which would increase the CTR threshold from $10k to $30k and index it going forward for inflation. It would also increase the SAR threshold from $5k to $10k. MCUL is educating members of our congressional delegation on the growing interest among credit union members and credit unions in cryptocurrency. We believe Congress should explore ways to regulate the delivery of financial services using digital currencies to ensure consumers are protected in the same way if they received financial services a financial institution. We urge Congress to look for ways to enable credit unions and other financial institutions to provide digital assets, so that these services can be properly overseen by federal regulators. Finally, credit unions seek parity with other financial institutions in this area as credit unions must be able to offer digital/crypto products and services directly to their members in the same way that other institutions can to their customers. Lastly, credit unions are non-for-profit member-owned financial institutions. Credit unions' consumer-focused model is self-regulating and a principal reason why credit unions are not covered by the Community Reinvestment Act (CRA). MCUL will educate members of the delegation of the work credit unions are doing to serve low/moderate-income, diverse communities and the negative impacts of including credit unions in the CRA. We will oppose efforts that would result in credit unions of any size being included in the CRA.

MCUL continues to educate members of the delegation on the importance of the credit union not-for-profit tax status to members and the benefits to non-members and how credit unions are different from other financial institutions. We oppose any efforts to change the credit union tax status/exemption in budget reconciliation legislation, including eliminating the tax exemption for "large credit unions" only. In addition, we continue to educate our delegation on the limited practice of credit unions purchasing bank assets and oppose any language in the budget reconciliation bill or elsewhere that would limit these purchases.

MCUL stands opposed to efforts to change the existing credit card interchange system by expanding requirements under the so-called Durbin Amendment established under the Dodd-Frank wall Street Reform and Consumer Protection Act of 2010. We have been educating our delegation on the importance of the current credit card interchange system with regard to ensuring consumer data remains secure and private and are asking our delegation to oppose any legislation of this type, including the Credit Card Competition Act. We continue to educate our congressional delegation on voluntary overdraft protection services offered by credit unions and the value our members place on these services. MCUL is opposed to legislation that would severely limit a financial institution's ability to offer these voluntary, opt-in services to our members who want access. MCUL is urging Congress to fully fund the CDFI program in FY27 and call on the Administration to release fund that were previously appropriated so awardees can utilize those dollars to carry out programs and services that assist people in need. We are also calling on Congress to improves program transparency, accountability and oversight. MCUL is supporting H.R. 3445, the Bureau of Consumer Financial Protection Commission Act, that would restructure the CFBP from a one director led agency to a 5-member commission led agency. MCUL is opposed to the 10 Percent Credit Card Interest Rate Cap Act (H.R. 1944/S.381) and is educating members of Congress on the negative impact the legislation would have on a substantial number of Americans, especially those with poor credit.