Update on Advocacy Action Plan Regarding CFPB’s Overdraft Rule

Posted by Gracie Nelson on March 1, 2024

Over the past month, GoWest has engaged in important discussions during Q1 GAC meetings and with key stakeholders. The primary concerns shared during this time have included:

1. The potential increase in fees on other products and services if the CFPB dictates pricing on overdraft, which would impact all members instead of just those who have opted into the overdraft service.
2. The proposed threshold would not exempt those credit unions due to marketplace competition.
3. The many consumer-friendly features of your individually designed member-centric overdraft products, which are vastly different than overdraft programs being highlighted in the

We have used these insights and feedback to inform you of an advocacy strategy designed to ensure that the CFPB hears your concerns.

Credit unions continue to share potential impacts and concerns regarding ODP including the risk of market competition distortion, the danger of pushing members towards predatory financial options, and the need to recognize the diverse economic realities faced by institutions of varying sizes.

That information will be used to draft the GoWest comment letter, which will strongly oppose the proposal and advocate for fair and balanced regulations that consider the unique structure of credit unions. This letter will be circulated to the Regulatory Advisory Committee and key stakeholders for feedback by March 10th.

In the upcoming days, nearly 500 GoWest credit union advocates will attend America’s Credit Unions’ GAC in Washington D.C. We will advocate directly to CFPB while we are in Washington, so we can share your concerns, emphasizing the detrimental impacts of the proposed rule.

Credit union leaders will advocate directly with Congress on this topic, providing education about the credit union structure, how that influences programs and services, and the potential impacts of credit unions being swept under regulations targeted toward the largest banks.

Following the advocacy efforts in Washington D.C., we will disseminate GoWest’s draft comment letter to the broader GoWest credit union family, seeking final input and feedback. We will then make any necessary revisions in preparation for submission by the comment due date on April 1st. We also encourage credit unions to consider writing their own response.

Opportunities for credit unions to advocate on this issue will not end when the comment period closes. The Spring Hike the Hill will include a meeting with the CFPB where we will continue to share direct feedback and requests. In addition, should a final rule come out that still presents serious concerns, credit union advocates can ask Congress to use their Congressional Review Act authority to rescind the rule.

Please continue to share feedback and examples of how this proposed rule may impact your credit union throughout the next several weeks. Thank you again for your engagement on this issue.

Posted in Advocacy on the Move, Regulatory Advocacy.