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The New York Credit Union Association has drafted comment letters on legislation and regulations that affect how our members do business. Read the letters below to find out more about our position.
Amendment of 23 NYCRR Part 500: Cybersecurity Requirements for Financial Services Companies (8/15/2023)
Fraudulently Altered Checks and UCC §4-207 Transfer Warranties (3/15/2023)
Request for Comment Second Amendment to 23 NYCRR 500 Cybersecurity Requirements for Financial Services Companies (1/9/23)
CDFI Fund letter: CDFI Target Market Assessment Methodologies (12/20/22) Comments to NCUA on Federal Credit Union Bylaws (12/2/22) Interest Rate Risk Evaluation and the continued use of the Net Economic Value Test (9/12/22) Request for Comment Draft Amendment to 23 NYCRR 500 - Cybersecurity Requirements for Financial Services Companies (8/22/22) Letter to Leader Schumer regarding Community Development Financial Institutions (CDFIs) (5/2/22) Request for Information Regarding “Vacation Policy as an Internal Control Safeguard” (3/8/22)
Capital Adequacy: The Complex Credit Union Leverage Ratio; Risk-Based Capital (175 KB) (10/15/21) Letter to Lt. Gov. Kathy Hochul - Vaccine Eligibility for CU Employees (155 KB) (3/15/21) Field of Membership—Shared Facility Requirements (2/10/21)
Opposition to New GSE Adverse Market Refinance Fees (283 KB) (8/25/20) NYCUA Letter in Support of Combination Transactions (8/13/20)
Response to Proposed Rulemaking, Chartering and Field of Membership (585 KB) (12/9/19) Letter to Sen. Schumer - NCUA taxi regulations review (243 KB) (5/30/19) Proposed Bylaw Amendments (1/14/19)
Payday Loans (299 KB) (7/31/18) Proposed 1st Amendment of Regulation 187 (11 NYCRR 244) (2/26/18)
NCUA proposal to close Stabilization Fund (226 KB) (9/5/17) NCUA proposed improvements to appeals process (1.20 MB) (8/7/17) Briggert-Waters Flood Insurance (1/6/17)
DFS Proposal on Zombie Properties (439 KB) (11/28/16) NYCUA-CUNA Cybersecurity Proposal (446 KB) (11/16/16) Wildcard letter to the DFS (362 KB) (10/27/16) CFPB payday loan proposal (311 KB) (10/5/16) NCUA proposal on extended exam cycle (255 KB) (8/4/16) Proposed Rulemaking for Parts 701 and 721, FCU Occupancy, Planning, and Disposal of Acquired and Abandoned Premises; Incidental Powers (380 KB) (6/24/16) FASB proposed CECL standard (364 KB) (3/21/16) Notice of Proposed Rulemaking Regarding Associational Common Bond (2/8/16)
Joint Letter to State AG on Chip and Pin Proposal (270 KB) (10/28/15) Department of Labor's proposal to raise exempt employee salary threshold (9/3/15) NCUA's proposed MBL amendments (8/27/15) NCUA's implementation on the Credit Union Share Insurance Fund Parity Act (265 KB) (7/15/15) CFPB on Integrated Mortgage (279 KB) (7/1/15) NCUA's small credit union definition (255 KB) (5/5/15) NCUA's Revised Risk-Based Capital Proposal (4/27/15) CFPB's Proposed Mortgage (841 KB) (3/19/15) FHLB Membership Amendments (1/12/15)
Chartering and Field of Membership Manual (278 KB) (6/30/14) NCUA's Risk‐Based Capital Proposal (184 KB) (5/28/14) Shared Appreciation Loan Modifications Proposal (133 KB) (1/31/14) In-Home Credit Union Proposal (1/23/14)
Flood Insurance Proposal (267 KB) (12/06/13) Interagency QRM Proposal (182 KB) (10/30/13) HUD QM Proposal (167 KB) (10/29/13) Derivatives Proposal (132 KB) (7/29/13) Fixed Assets Proposal (97 KB) (5/16/13) Qualified Mortgage Amendments (188 KB) (2/25/13) Remittance Transfer Requirements (60 KB) (1/30/13) Ability to Pay (1/7/13)
Investment in Treasury Investment Protected Securities (83 KB) (TIPS) (11/26/12) Payday Alternative Loans (88 KB) (PALs) (11/26/12) CFPB Streamlining Regs Comment Letter (207 KB) (3/5/12) TDR Proposal Comment Letter (178 KB) (3/2/12) RegFlex Program Comment Letter (44 KB) (2/27/12) Loan Participation Comment Letter (55 KB) (2/16/12) Emergency Liquidity Comment Letter (2/16/12)
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Comment Letters
The New York Credit Union Association has drafted comment letters on legislation and regulations that affect how our members do business. Read the letters below to find out more about our position.
Amendment of 23 NYCRR Part 500: Cybersecurity Requirements for Financial Services Companies (8/15/2023)
Fraudulently Altered Checks and UCC §4-207 Transfer Warranties (3/15/2023)
Request for Comment Second Amendment to 23 NYCRR 500 Cybersecurity Requirements for Financial Services Companies (1/9/23)
CDFI Fund letter: CDFI Target Market Assessment Methodologies (12/20/22)
Comments to NCUA on Federal Credit Union Bylaws (12/2/22)
Interest Rate Risk Evaluation and the continued use of the Net Economic Value Test (9/12/22)
Request for Comment Draft Amendment to 23 NYCRR 500 - Cybersecurity Requirements for Financial Services Companies (8/22/22)
Letter to Leader Schumer regarding Community Development Financial Institutions (CDFIs) (5/2/22)
Request for Information Regarding “Vacation Policy as an Internal Control Safeguard” (3/8/22)
Capital Adequacy: The Complex Credit Union Leverage Ratio; Risk-Based Capital (175 KB) (10/15/21)
Letter to Lt. Gov. Kathy Hochul - Vaccine Eligibility for CU Employees (155 KB) (3/15/21)
Field of Membership—Shared Facility Requirements (2/10/21)
Opposition to New GSE Adverse Market Refinance Fees (283 KB) (8/25/20)
NYCUA Letter in Support of Combination Transactions (8/13/20)
Response to Proposed Rulemaking, Chartering and Field of Membership (585 KB) (12/9/19)
Letter to Sen. Schumer - NCUA taxi regulations review (243 KB) (5/30/19)
Proposed Bylaw Amendments (1/14/19)
Payday Loans (299 KB) (7/31/18)
Proposed 1st Amendment of Regulation 187 (11 NYCRR 244) (2/26/18)
NCUA proposal to close Stabilization Fund (226 KB) (9/5/17)
NCUA proposed improvements to appeals process (1.20 MB) (8/7/17)
Briggert-Waters Flood Insurance (1/6/17)
DFS Proposal on Zombie Properties (439 KB) (11/28/16)
NYCUA-CUNA Cybersecurity Proposal (446 KB) (11/16/16)
Wildcard letter to the DFS (362 KB) (10/27/16)
CFPB payday loan proposal (311 KB) (10/5/16)
NCUA proposal on extended exam cycle (255 KB) (8/4/16)
Proposed Rulemaking for Parts 701 and 721, FCU Occupancy, Planning, and Disposal of Acquired and Abandoned Premises; Incidental Powers (380 KB) (6/24/16)
FASB proposed CECL standard (364 KB) (3/21/16)
Notice of Proposed Rulemaking Regarding Associational Common Bond (2/8/16)
Joint Letter to State AG on Chip and Pin Proposal (270 KB) (10/28/15)
Department of Labor's proposal to raise exempt employee salary threshold (9/3/15)
NCUA's proposed MBL amendments (8/27/15)
NCUA's implementation on the Credit Union Share Insurance Fund Parity Act (265 KB) (7/15/15)
CFPB on Integrated Mortgage (279 KB) (7/1/15)
NCUA's small credit union definition (255 KB) (5/5/15)
NCUA's Revised Risk-Based Capital Proposal (4/27/15)
CFPB's Proposed Mortgage (841 KB) (3/19/15)
FHLB Membership Amendments (1/12/15)
Chartering and Field of Membership Manual (278 KB) (6/30/14)
NCUA's Risk‐Based Capital Proposal (184 KB) (5/28/14)
Shared Appreciation Loan Modifications Proposal (133 KB) (1/31/14)
In-Home Credit Union Proposal (1/23/14)
Flood Insurance Proposal (267 KB) (12/06/13)
Interagency QRM Proposal (182 KB) (10/30/13)
HUD QM Proposal (167 KB) (10/29/13)
Derivatives Proposal (132 KB) (7/29/13)
Fixed Assets Proposal (97 KB) (5/16/13)
Qualified Mortgage Amendments (188 KB) (2/25/13)
Remittance Transfer Requirements (60 KB) (1/30/13)
Ability to Pay (1/7/13)
Investment in Treasury Investment Protected Securities (83 KB) (TIPS) (11/26/12)
Payday Alternative Loans (88 KB) (PALs) (11/26/12)
CFPB Streamlining Regs Comment Letter (207 KB) (3/5/12)
TDR Proposal Comment Letter (178 KB) (3/2/12)
RegFlex Program Comment Letter (44 KB) (2/27/12)
Loan Participation Comment Letter (55 KB) (2/16/12)
Emergency Liquidity Comment Letter (2/16/12)
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