I have read several articles and opinions recently looking back at the creation of the CFPB and the part credit unions played in the process. Certainly today, it would be hard to argue that the CFPB has not created an additional paperwork and regulatory burden. When talk of a new consumer protection agency started here in Washington back in 2009, my first reaction was likely the same as many others working in and around the financial services industry. I was wary of increased regulatory burden and was certain we did not need another layer of bureaucracy and red tape. Regardless, we were certain there would be a substantive and swift reaction to the 2008 meltdown. In the lead up to Dodd-Frank, and the subsequent creation of the CFPB, CUNA worked closely with credit union industry representatives across the country to assess the political realities and develop a strategy to navigate through a rapidly changing landscape.

At CUNA we weighed the likelihood that the CFPB would become a reality and the extent to which it would have authority over credit unions. With a newly elected president and new majorities in the Senate and the House, it was more than reasonable to conclude that something was going to be enacted into law and that credit unions could not avoid inclusion. It should also be noted that the credit union system was not united on many aspects of Dodd-Frank including the creation of the CFPB. In fact several of the system's largest credit unions were on opposite sides of the issue.

For this reason, CUNA engaged the leaders in the Senate and the House to seek credit union friendly modifications to the pending legislation, and testified three times on the proposal. Once we realized the force behind creation of the CFPB and the fact that credit unions would be included in its focus, working against it completely would have been a fool's errand, akin to advocating for an endless summer. Of course it sounds great and many people would be on board, but the prudent citizen would prepare for Fall and Winter as usual.