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Advocacy in Action

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Why NACUSO Shows Up in Washington

Each year, thousands of credit union leaders gather in Washington, D.C. for the Governmental Affairs Conference (GAC). While the conference is known for its energy, scale, and tradition, at its core GAC represents something far more important: the collective voice of the credit union movement engaging directly with policymakers about the future of our industry.

This year, NACUSO was proud to be part of that conversation.

For the CUSO community, advocacy matters. Credit Union Service Organizations have long been one of the credit union system’s most powerful tools for collaboration, innovation, and scale. From lending platforms and payments infrastructure to insurance and operational services, CUSOs allow credit unions to work together to build solutions that none could create alone.

Yet despite how much the industry has evolved, the regulatory and statutory framework governing CUSOs has largely remained unchanged for decades. That is why NACUSO continues to ensure that the voice of the CUSO community is represented in policy conversations in Washington.

Throughout the week at GAC we spent time engaging with industry partners, regulators, and policymakers about the role CUSOs play in strengthening credit unions and expanding their ability to serve members. A central theme of these conversations was the need to modernize policies that affect credit union collaboration and innovation.

In particular, NACUSO continues to advocate for reforms that would modernize the CUSO investment cap, which today limits how much credit unions can invest in collaborative ventures designed to benefit the broader system. While the details of any potential legislative approach are still evolving, one encouraging takeaway from this year’s conference was the growing recognition across the credit union ecosystem that modernization may be necessary to reflect how CUSOs operate today.

Another recurring theme during the week was the importance of data and transparency around the CUSO sector. As policymakers increasingly evaluate how collaboration and innovation function within financial services, having reliable information about the scale and impact of CUSOs will be critical in shaping future regulatory discussions.

Perhaps the most encouraging aspect of the week, however, was the broader spirit of collaboration across the industry. Credit union leagues, trade associations, regulators, and policymakers all share a common goal: ensuring that credit unions remain strong, innovative, and capable of serving their members in an increasingly competitive financial marketplace.

CUSOs are a vital part of that equation.

They represent the credit union system’s ability to pool resources, share risk, and create solutions that benefit the entire movement. As new technologies emerge and financial services continue to evolve, the role of CUSOs in supporting credit union innovation will only grow more important.

That is why NACUSO’s advocacy efforts remain so critical. Ensuring that policymakers understand the value of collaboration—and the role CUSOs play in enabling it—is essential to protecting and expanding the opportunities available to credit unions in the future.

The conversations that begin at events like GAC rarely end there. Instead, they serve as the starting point for the ongoing work of education, coalition-building, and policy development that takes place throughout the year.

For NACUSO, that work continues.

Because when credit unions collaborate, the entire system becomes stronger—and advocacy ensures that the framework supporting that collaboration continues to evolve alongside the industry it serves.

Interested in supporting our efforts on Capitol Hill?  NACUSO Advocacy Fund

“uncertainty does create an opportunity for credit unions and CUSOs to leverage their collaborative relationships”


Support NACUSO’s Advocacy Efforts

NACUSO is committed to ensuring that CUSOs, credit unions, and their service partners have a strong, unified voice in regulatory and legislative conversations—especially as rules around innovation, data sharing, and consumer choice continue to evolve.

Your support makes this work possible.
If your organization believes in the importance of thoughtful, future-focused advocacy, please consider contributing to the NACUSO Advocacy Fund. Together, we can shape a regulatory environment that empowers collaboration and keeps credit unions competitive.

Learn more or contribute today.

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Open Banking Reconsidered

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The CFPB takes another look—while CUSOs & credit unions prepare for a rule that may (or may not) take shape.

The regulatory rollercoaster ride of the CFPB’s Personal Financial Data Rights rule, commonly known as its open banking rule, has had many twists and turns along the way.  The process to implement this on-again, off-again rule is back to being on-again…sort of.  

The CFPB finally finalized the open banking rule in October 2024 after being directed by the Dodd-Frank Act (of 2010!) to issue rules that grant consumers greater control over certain financial data.  The rule was also intended to promote fair, open, and inclusive industry standards to facilitate open banking.  The day the rule was finalized, a lawsuit was filed asserting that the CFPB had exceeded its statutory authority in issuing the rule.  The CFPB under the Trump administration ultimately moved to stay proceedings, essentially halting the lawsuit.  It promised to reconsider the rule to address some of the agency’s major concerns.  On August 22, the CFPB released a notice of proposed rulemaking to reconsider its open banking rule.  The agency is seeking comment on four issues it has determined are pressing in its reconsideration of the rule:

  1. Understanding who can request data on behalf of a consumer;
  2. If and how fees can be assessed by the entity responding to the consumer’s request to share data (typically, the financial institution);
  3. How to address data security concerns with sharing such data; and
  4. If the current rule provides adequate protections for consumer privacy.    

Got all of that?

So what is all of the hubbub about? 

What even is “open banking”? 

It happens to be an increasingly popular data sharing framework in banking across the globe.  As stated by the CFPB in its October 2024 final rule, it is essentially a network of entities that share personal financial data (typically through application programming interfaces or APIs) with a consumer’s prior authorization.  This includes financial institutions and other types of non-depository institutions (i.e. fintechs).

Why is it all of this important for credit unions and CUSOs?  First of all, even though the CFPB is currently reconsidering the parameters of its open banking rule, its statutory obligation to issue a rule to grant consumers greater control over their financial data has not changed.  Therefore, although the implementation timeline is murky, it is industry expectation that there will still be some sort of final open banking rule.  Further, even though the rule is currently in a gray area, credit union member demand for frictionless, easily portable, innovative financial digital solutions remains.  So there is an opportunity here for credit unions and CUSOs to get ahead of the curve by continuing to assess, develop, and implement member-driven consent frameworks.  It has been industry mantra for over a decade, but it also remains essential to understand and categorize member data.  In anticipating potential compliance requirements under this rule, it is best practice to understand what member data your institution shares with third parties, how your institution shares member data with third parties, how that data sharing access is secured, and how these responsibilities are addressed in your agreements with these third parties.  

Although there is currently no clear end in sight for this regulatory rollercoaster ride, the uncertainty does create an opportunity for credit unions and CUSOs to leverage their collaborative relationships to offer, and to even create, better products and services for their members in a secure manner.  

“uncertainty does create an opportunity for credit unions and CUSOs to leverage their collaborative relationships”


Support NACUSO’s Advocacy Efforts

NACUSO is committed to ensuring that CUSOs, credit unions, and their service partners have a strong, unified voice in regulatory and legislative conversations—especially as rules around innovation, data sharing, and consumer choice continue to evolve.

Your support makes this work possible.
If your organization believes in the importance of thoughtful, future-focused advocacy, please consider contributing to the NACUSO Advocacy Fund. Together, we can shape a regulatory environment that empowers collaboration and keeps credit unions competitive.

Learn more or contribute today.