Do you know what the Proposed #CUSO Rule Means for #CreditUnion #AutoLending?


Short answer the proposal would allow CUSOs to originate ALL type of loans - including auto Loans for the very first time - if made final.


Currently CUSOs can only originate:

business consumer mortgage and credit cards.


Per the proposal:


The rule would accomplish two objectives:

(1) expanding the list of permissible activities and services for #CUSOs to include originating any type of loan that a federal credit union (FCU) may originate

and

(2) granting the #NCUA Board additional flexibility to approve permissible activities and services.


Board approved by a 2-1 vote (Harper voting no)


The NCUA is also seeking comment on broadening FCU investment authority in CUSOs. Short comment period of 30 days...More to follow ...


If you would like to discuss this or your current challenge, message me here or at info@marktreichel.com and we can set up a free strategy session.


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Here are more details from the NCUA Board Action Memorandum (BAM):


SUMMARY: The proposed rule would amend the NCUA’s regulation regarding CUSOs. The proposed rule would accomplish two objectives: (1) expanding the list of permissible activities and services for CUSOs to include originating any type of loan that a federal credit union (FCU) may originate; and (2) granting the Board additional flexibility to approve permissible activities and services outside of notice-and-comment rulemaking. The NCUA is also seeking comment on broadening FCU investment authority in CUSOs.


Link to the CUSO BAM:


https://www.ncua.gov/files/agenda-items/AG20210114Item2a.pdf



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Here are more details on why the NCUA Board proposed this rule:


"To compete effectively in a market with a rising prevalence of these technology-based lenders, FCUs may need to rely increasingly on pooling their resources to fund CUSOs and to build the necessary infrastructure. The costs for research and development, acquisition, implementation, and specialized staff capable of managing these new technologies may be prohibitive for all but a very few of the largest FCUs. CUSOs may provide the means for FCUs to address these challenges and may enable FCUs to collaboratively develop technologies that better serve their members.

The Board recognizes that CUSOs provide significant value to the credit union industry by facilitating cooperation among credit unions. With CUSOs’ collaborative business model, CUSOs are able to foster shared innovation among credit unions to achieve economies of scale, develop expertise, and better serve their members. These attributes allow CUSOs to offer financial services to credit union members more efficiently than an individual credit union may otherwise be able to offer, particularly for small credit unions.30 The cooperation and transfer of knowledge among credit unions through CUSOs can have long-term positive implications for the safety and soundness of the credit union system."


The entire text of the proposed CUSO rule can be found here:


https://www.ncua.gov/files/agenda-items/AG20210114Item2b.pdf