New Hampshire Commissioner of Banks Releases Letters on New Legislation

New Hampshire Commissioner of Banks Jerry Little recently released two industry letters to provide guidance on recently enacted legislation as it impacts state chartered institutions. The Association worked closely with members to build a consensus on the legislation introduced by the Banking Department (“Department”) and testified in support during the public hearing process.

The passage of the new law takes effect on October 9, 2021. 

With respect to consumer complaints, RSA 383-A:9-904 has been amended and changes how the Department will be transmitting consumer complaints to credit unions. The regulatory guidance may be found at: Banking Department Guidance on Consumer Complaint Transmission

Notably, the Association advocated for its shared goals with the Department to preserve the optimum security of private member information. Accordingly, a secure electronic portal to be used in the transmission process of consumer complaints was mutually agreed upon.

Upcoming Consumer Complaint Key Deadlines:

September 17, 2021: Deadline to provide the Department with the name and email address of the credit union’s point of contact for the receipt of consumer complaints. This information should be sent to Doreen Sheppard at legal@banking.nh.gov.

September 24, 2021: Deadline to receive a test email from the Department using the test email contact address provided. This email will be sent by the following Department’s email address: legal@banking.nh.gov. Credit unions are encouraged to add this address to their email contacts to prevent Department emails being sent to junk folders or spam filters. If the test email is not received by the designated contact by September 24, 2021, then please contact Doreen Sheppard.

October 9, 2021: The Department will no longer send complaints by certified mail. Complaints will be sent by secure email.

With respect to fees, the new law changes the fee accessed by the Department for review of an application to charter new institutions. The fee will increase from $10,000 to $15,000. Additional fees may be accessed if the cost for review of any application or notice exceeds the statutory filing fee charged. The Department will provide notice and the opportunity to withdraw a filing whenever the cost for review has or is expected to exceed the statutory filing fee. Additional charges will be based on the per diem examination fee established under RSA 383:11, I. Finally, the new law also clarifies that a chartered institution that dissolves or converts from state to federal charter is responsible for payment of its share of incurred assessment under RSA 383:11, II.

The regulatory guidance may be found at: Banking Department Guidance on Fees

As a reminder relative to fees, the Association is pleased that the Department also recently released recent guidance on examination assessments. Pursuant to state law and the Department’s policy and procedure, the per diem fee for all state chartered credit unions has been calculated to be $908. This new per diem fee represents a $166 or 15.5% decrease from the current fee and will be charged for all examinations commencing on or after October 1, 2021. This issue was part of the Association’s successful state legislative advocacy platform. The regulatory guidance may be found HERE

All of this information has also been posted on the Department’s website, www.nh.gov/banking.

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