S. 2155 Signed into Law One Year Ago: What’s the Status of Regulatory Relief?

One year ago today, President Donald Trump signed into law the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155). The signed legislation was the result of one of the credit union movement’s historic advocacy campaigns, the result of thousands of hours of work from CUNA, credit union leagues, credit unions and members.

The bill first saw the light of day a bipartisan agreement between Senate Banking Committee Chair Mike Crapo (R-ID) and Sens. Joe Donnelly (D-IN), Heidi Heitkamp (D-ND), Jon Tester (D-MT) and Mark Warner (D-VA) that resulted in several regulatory relief provisions, most notably one that would grant credit unions member business lending cap relief.

At the start of 2018, CUNA engaged in a comprehensive grassroots campaign to garner support for the bill, including through CUNA’s Campaign for Common-Sense Regulation, letters to legislators, and league and credit union-placed op-eds and letters to local newspapers. This also included a White House visit with Trump that included CUNA President/CEO Jim Nussle and credit union representatives during the 2018 CUNA Governmental Affairs Conference.

The push paid off as the Senate, for one of the only times during the 115th Congress, passed the bill with a bipartisan 67-31 vote shortly after CUNA's GAC. The House followed suit in May, passing the bill with a 258-159 vote.

In the year since Trump signed the bill into law, many of the credit union regulatory relief provisions have been made official through regulatory rulemakings, and some are still in process.

Here’s the status of those provisions from the agencies responsible:


  • Exempting loans made on one-to-four- unit, non-owner- occupied residential dwellings from the member business loan cap.

        Status: Complete, as NCUA passed a rule by notation vote in the days following S. 2155 enactment into law.

  • Exempting certain mortgage loans of less than $400,000 on property located in rural areas where no appraiser is available from the appraisal requirement.

        Status: This section is self-implementing, so credit unions have been able to take advantage of it since the law was enacted. While a regulation is not required, NCUA proposed a rule in September 2018 to incorporate the exemption into its regulations, it has not been finalized. CUNA submitted a comment letter.  

  • Requiring NCUA to publish a draft budget and hold a hearing on the budget prior to submitting the budget.

        Status: This became effective immediately upon enactment of S. 2155 and does not require a rulemaking.


  • Clarifying that the same consumer protections in place with respect to mortgage lending are nonexistent for Property Assessed Clean Energy (PACE) loans.

        Status: The CFPB has issued an advance notice of proposed rulemaking to begin the process of regulating PACE loans, and CUNA submitted a comment letter.

  • Rescinding the additional data points required under the Home Mortgage Disclosure Act for insured credit unions that originate fewer than 500 closed-end and/or 500 open-end lines of credit.

        Status: The CFPB issued a final interpretive rule in August 2018 clarifying the partial exemptions in S. 2155. Reporting of these additional data points is scheduled to begin in 2019 for all other financial institutions, but exempt credit unions will not need to report that data.

Other provisions:

  • Providing a safe harbor for properly trained financial employees who report alleged elder financial abuse;

        Status: CUNA has teamed up with AARP to offer BankSafe, a free online training platform tom help credit union employees better understand the signs of elder financial exploitation.