Happy National Compliance Officer Day to those who celebrate!
Another week, another round of regulatory cliffhangers. With the federal government careening towards a shutdown, flood insurance authorization about to lapse, and the CFPB rolling out an aggressive regulatory agenda, credit unions have plenty on their plates. Oh, and don’t forget about that little rate cut that got a bit of news.
So, grab that second cup of coffee or chai and let’s break down what’s mattered for your credit union radar over the past couple of weeks.
Potential Federal Government Shutdown
Let’s hope this one stays theoretical and on Wednesday morning we can talk about how Congress passed an appropriations bill in the nick of time.
Congress has until September 30 to pass appropriations bills for FY2026 or enact a continuing resolution to avoid a government shutdown. The House passed a short-term funding measure, but the Senate rejected it before they headed home for a one-week recess, scheduled to return September 29.
Non-essential federal operations would halt, furloughing thousands of federal workers nationwide, including many in New York.
As with prior shutdowns, credit unions may serve federal employees through special loan programs, payment flexibility, and financial counseling services. Branches in federal buildings may face access issues.
Essential services and mandatory programs will continue, but regulatory approvals and federal agency disbursements could face delays.
National Flood Insurance Program Authorization Expires September 30, 2025
The NFIP’s authorization expires the same day as the government funding deadline, a double whammy for real estate markets.
During a lapse, borrowers will not be able to purchase new flood insurance contracts, but existing policies remain valid and claims—funds permitting—continue to be paid.
Credit unions must still conduct flood determinations and should provide required disclosures.
CFPB Releases Its Regulatory Agenda
The CFPB unveiled its Spring Unified Agenda with 24 regulatory initiatives. Here are some highlights:
Key Proposed and Pre-Rule Initiatives for Credit Unions:
- Personal Financial Data Rights (Section 1033): Open banking rule under reconsideration after being paused in July 2025.
- Small Business Lending Data Collection (Section 1071): Compliance dates already extended, but further revisions may be coming.
- UDAAP Rulemaking: Potential redefinition of unfair, deceptive, or abusive practices under Section 1031.
- Equal Credit Opportunity (Regulation B): Potential clarification of obligations imposed by the Equal Credit Opportunity Act.
- Mortgage Servicing Streamlining: Final rules expected to ease servicing for borrowers with payment difficulties.
- Fair Credit Reporting (Regulation V): Proposals addressing identity theft and coerced debt.
Wrapping It Up
Between a possible federal government shutdown, flood insurance uncertainty, and some ambitious rulemakings, credit unions have plenty to track before the calendar turns to October. Add a dash of pumpkin spice and you’ve got a recipe for a Fall full of moving pieces.
Let’s Make This Useful
I want this blog to be as relevant as possible to the people reading it. So:
- Got a topic you’d like me to break down?
- Burning desire to know more about that headline you read the other day?
- Have an industry-related question you want addressed?
Reach out to me at jeremy.newman@nycua.org. Let’s talk.
Until Next Time
From the big picture to the fine print, we’ve got you covered. Thanks for reading, and CU in the next post.