The Center for Responsible Lending (CRL), Self-Help Federal Credit Union, Self-Help Credit Union, and the National Consumer Law Center (on behalf of its low income clients) (NCLC) write to share concerns with the Interim Final Rule on Overdraft Policy that was considered and tabled at NCUA’s May Board meeting. Unfortunately, the proposal fails to offer members relief from overdraft fees so desperately needed during the COVID-19 crisis, while subjecting members to additional risks from overdraft programs. In addition, as an interim final rule, the proposal would inappropriately bypass the notice and comment period warranted for any proposal that could increase harm to members from overdraft practices.
