WASHINGTON— America’s Credit Unions said Monday it has filed six comment letters backing a new round of NCUA deregulation proposals, urging the agency to strip out what it called outdated, duplicative or overly prescriptive rules while preserving key operational flexibilities for federal credit unions.
See links to the letters below, along with a summary provided by ACU:
- America’s Credit Unions supports rescinding the regulation that authorizes federal credit union boards to issue interest refunds to members because it duplicates the FCU Act but asks the NCUA to preserve a board's authority to vary refunds by loan type through guidance, retention of the relevant subsection, or a statutory amendment.
Compensation in connection with loans and lines of credit to members
- Comments support the NCUA's proposed modernization of the regulation governing official and employee compensation tied to credit union loans. America’s Credit Unions asks the agency to define key safety-and-soundness terms, confirm that lending metrics may be used within a broader performance framework, and ensure consistent examiner application.
Credit union service contracts
- The letter supports deleting the regulation governing federal credit union service contracts as duplicative of statutory authority under the FCU Act, and America’s Credit Unions asks the NCUA to codify a credit union's authority to act as a representative in shared service agreements under NCUA’s incidental powers regulation.
Post-election training for new board members
- America’s Credit Unions supports eliminating the regulation requiring new federal credit union directors to attain a working familiarity with finance and accounting within six months of election because the requirement is overly prescriptive, and credit unions are better positioned to set their own board training standard. The letter also notes that the continued application of the CAMELS rating system to board capability, the fiduciary duties imposed on directors under federal credit union bylaws, and the strong self-interest credit unions have in thoroughly training directors address potential safety and soundness concerns.
Purchase, sale, and pledge of eligible obligations
- Comments support removing the prescriptive list of items required in federal credit union written policies governing the purchase, sale, and pledge of eligible obligations, along with the duplicative conflict-of-interest and compensation provisions already covered by bylaws.
- The letter supports removing the preemption-related definition in the regulation governing federal credit union statutory liens, as it is redundant and potentially confusing alongside other applicable state and federal laws.