March 11, 2021 Commissioner of Financial Protection and Innovation Attn: Regulations Coordinator, Legal Division 300 So. Spring Street, Suite 15513 Los Angeles, CA 90013 Via:
[email protected] Re: Comments on Modified Proposed Regulations Concerning Credit Union Regulations Dear Commissioner Alvarez, I am writing on behalf of the California Credit Union League (League), one of the largest state trade associations for credit unions in the United States, representing the interests of approximately 230 California credit unions and their more than 11.6 million members. On June 26, 2020, the California Department of Financial Protection and Innovation (DFPI), formerly known as the California Department of Business Oversight (DBO), issued proposed amendments to Title 10, Chapter 1, Subchapter 30, of the California Code of Regulations (CCR) pertaining to credit unions. On February 24, 2021, the DFPI proposed further amendments to the regulations based on the initial comments received. The League has significant concerns with certain components of the proposed amendment language, and strongly opposes the proposed investment limit of 10 percent of the credit union’s equity capital in amended 10 CCR §30.300. We offer the following comments and recommendations. I. Investments – 10 CCR §30.300(b) A. 10 Percent Limitation on Investment Activities Under the proposal, a credit union is authorized to: “[I]nvest in securities issued by any person, as that term is defined in Section 14001.1 of the Financial Code, subject to the limitation that the credit union’s total investments in the securities issued by any one person shall not exceed 10 percent of the credit union’s equity capital, as that term is defined in Section 14400 of the Financial Code.” The following outlines our specific issues regarding the 10 percent limitation: a.