Heading into 2017, credit union officials are left with more questions than answers about the regulatory climate they will face in the New Year.
The enforcement people may change.
New regulations may be delayed.
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Already issued regulations may even be rolled back.
"When it comes to the regulators, there's definitely uncertainty," NAFCU Director of Regulatory Affairs Alexander Monterrubio said.
"There are a lot of unknowns," CUNA Chief Advocacy Officer Ryan Donovan added. "There's always uncertainty, particularly when you have a change in party control.
At the NCUA, there's likely to be a new chairman and there's a reasonable chance it will be current board member J. Mark McWatters — that is unless McWatters is confirmed for a seat on the Export-Import Bank. Then, all bets are off.
"Twelve months from now, we could have a whole new board," Donovan said.
While the NCUA board recently issued final rules amending its field of membership standards, the board also proposed additional changes and comments are now being solicited for those additional amendments.
For instance, the final rules did not propose expanding the community charter core area population limit beyond 2.5 million. However, the proposed rule would increase the population limit to 10 million on a well-defined local community other than a single political jurisdiction.
The proposed rule would also allow applicants seeking approval to initially form, expand or convert to a community charter or have the option of submitting a narrative to establish the required common bonds instead of relying on a "presumptive community" standard.
A new board chairman and board members could significantly amend any final FOM rule that might be issued.
However, if the only immediate change is McWatters being elevated to chairman, drastic changes are unlikely, since he has a good working relationship with current Chairman Rick Metsger, Monterrubio said.
"All of those things seem to have bipartisan support," he said.
But if there are more changes than simply a change in chairmen, then anything could happen.
Things may be even more dicey at the CFPB.

"Perhaps there's a greater deal of uncertainty there," Donovan said.
A federal appeals court has ruled that the structure of the CFPB is unconstitutional since its director may only be removed for cause. However, the agency has appealed the ruling, which will not be enforced until the case is finally decided.
And so, Richard Cordray — whom many Democrats like and Republicans don't like — will remain in charge. He was confirmed by the Senate in 2013 for a five-year term.
If Cordray were to leave, President-elect Donald Trump would nominate a replacement. Trump has vowed to dismantle the Dodd-Frank Act, so any director Trump would nominate likely would not be as aggressive as Cordray has been.
The CFPB has several major regulations pending that could be affected by any change in director.
For instance, the agency is expected to release controversial rules governing mandatory arbitration agreements in employment and financial contracts early next year.
Those rules could be affected by any change in director.
The agency also is reviewing comments submitted on its controversial payday lending rules. No timetable for final rules has been established.
And here's another wild card — Congress.
Congressional Republicans are no fans of the CFPB and have attempted to rein in the agency by making it subject to the appropriations process or convert it to a five-member commission.
And House Republicans have vowed to try to block the agency from issuing final arbitration and payday lending rules.
But on the Senate side, Sen. Elizabeth Warren (D-Mass.) has vowed to fight any effort to weaken Dodd-Frank or the CFPB.
And if that's not head-spinning enough, congressional Republicans have a little-used law, the Congressional Review Act, at their disposal.
That law includes provisions that would enable Congress to overturn agency final rules issued in the closing months of an administration. Such rules are known as "midnight regulations."
The law has only been used successfully once since its enactment when Department of Labor regulations governing ergonomics in the workplace were overturned.
Monterrubio and Donovan said they do not believe that any final rules issued by the NCUA or the CFPB are likely to be targets for Republicans interested in using the Congressional Review Act.
"I don't see that many opportunities," Monterrubio said.
However, they acknowledged that there has been some discussion about whether opponents of the Department of Labor's controversial overtime regulations could be challenged under the law.
House Republicans have proposed legislation that would make it even easier for Congress to overturn such rules, but President Obama has vowed to veto the measure.
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