May 7, 2013
The Honorable Richard Cordray
Director
Consumer Financial Protection Bureau
1700 G Street, NW
Washington, DC 2055
RE: Student Loan Borrowers – May 8, 2013 Field Hearing
Dear Director Cordray:
On behalf of the National Association of Federal Credit Unions (NAFCU), the only trade association that exclusively represents federal credit unions, I would like to submit this letter for the record in connection with the Consumer Financial Protection Bureau (CFPB) May 8, 2013 field hearing, to be held in Miami, Florida.
As I’m sure you are aware, The National Credit Union Administration (NCUA) recently wrote an article in their March edition of the NCUA Report stating that the private student loan market nationwide has a total delinquency (loans past due more than 60 days) of 5.4%, while the total delinquency for credit unions is significantly lower at 1.46%. Unlike other financial institutions, credit unions are philosophically, structurally, and financially incentivized like no other financial institution to be responsive to the individual needs of its members. Credit unions work with their members to ensure they are in an appropriate product and have an interest in building a life-long financial relationship with that individual.
While credit unions as an industry are united by a focus on their members, each credit union and its members are different. Some credit unions have unique relationships with universities because their field of membership that includes students interested in private student loans. Other credit unions don’t have a large student population, but may have a member with a son or daughter who is thinking about going to college. We urge the CFPB to think seriously before introducing any proposal that applies a one size fits all approach to private student lending without giving credit unions the flexibility to best serve their members.
We thank you for your time and the opportunity to submit this letter as part of the official record of the May 8, 2013 field hearing. If you have any questions or concerns, please feel free to contact me at (703) 842-2212 or via email at PJHoffman@nafcu.org.
Sincerely,
PJ Hoffman
Regulatory Affairs Counsel
National Association of Federal Credit Unions