WASHINGTON—America’s Credit Unions is supporting NCUA’s proposed modernization of its records preservation rule, saying the changes would clarify that the regulation is focused on vital records needed to restore member services after a catastrophic event—not on creating a broader record-retention mandate.
In a Monday letter to the agency, America’s Credit Unions Regulatory Advocacy Senior Counsel Luke Martone said the proposal would appropriately update Part 749 by removing nonbinding guidance from the regulatory text while preserving flexibility for credit unions to use current records management and recovery practices.
ACU said removing Appendices A and B would clear up confusion and reduce unnecessary burden because the appendices were intended as guidance but have often been treated as mandatory. The trade group said those materials should instead be updated and maintained separately as nonbinding guidance, FAQs or training materials.
ACU also emphasized that older versions of vital records may be destroyed unless another law or regulation requires retention, and that identifying a record as “vital” does not mean it must be kept permanently. ACU said any final rule should support modern practices—including electronic logs, automated backups, third-party providers and documented procedures—while maintaining flexibility for credit unions of different sizes, especially smaller institutions with limited staff and storage resources.