9 THE NAFCU JOURNAL JULY–AUGUST 2022 Unfinished Business: The Dodd-Frank Act In terms of other rulemaking, unfinished business from the Dodd-Frank Act will be the focus. The CFPB will continue to forge ahead with its Section 1071 rule on small business data collection and the Section 1033 rule on consumer access to personal financial data, also referred to as the Bureau’s foray into making open banking a reality for consumers sooner rather than later. We’ve heard that the Section 1033 rulemaking, has been bogged down, understandably, by concerns surrounding data privacy and protection. Pushing the UDAAP Boundaries As referenced above, the CFPB in March announced changes to its examination procedures to target non-credit discrimination outside of the scope of the Equal Credit Opportunity Act as it claims this sort of discrimination may be an “unfair” act or practice. We fully anticipate the Bureau will continue to push the bounds of its UDAAP authority through similar pronouncements to advance the Biden Administration’s priorities regarding equity, inclusion, and access to financial services. Bottom line is, so far, we at NAFCU are not overly concerned by what Director Chopra has done, but we have every right to be worried about what may be headed our way soon. With all of their direct messaging through blog posts, RFIs, and appearances on CNBC, the past few months have been an exercise in laying the groundwork for what’s to come. I do not mean to frighten you, but I am warning you that this will be no walk in the park. Never hesitate to reach out to NAFCU’s Regulatory and Compliance teams should you have any questions or concerns. We’re here to serve you and will continue to be a strong advocate for you in Washington. NAFCU has a complimentary, memberonly online community exclusively for leaders involved in examinations at NAFCU member credit unions above $5 billion in assets. Learn more about the NAFCU ONES + CFPB Supervision Network at www.nafcu.org/ones-network.
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