WASHINGTON–CUNA has filed separate comment letters with NCUA on the Central Liquidity Facility and asset thresholds, respectively.
In the first letter, CUNA commented on the agency’s regulations to reflect extensions of CARES Act provisions made by the Consolidated Appropriations Act.
“We agree with Chairman Harper’s position that the CLF provisions first incorporated into the CARES Act that should be made permanent,” CUNA wrote. “We echo the Chairman’s remark that ‘permanence would provide regulatory uncertainty during the current crisis and bolster the credit union system’s ability to respond to future emergencies.’”
In its second letter, CUNA said it also supports NCUA’s IFR regarding the measurement of assets for determining applicability of certain regulatory requirements.
As CUNA noted, to mitigate transition costs on credit unions related to the pandemic, the IFR permits credit unions to use asset data as of March 31, 2020, in order to determine the applicability of certain regulatory asset thresholds during calendar years 2021 and 2022. Specifically, the IFR allows a credit union to use March 31, 2020, financial data when determining whether it is subject to capital planning and stress testing requirements and supervision from NCUA’s ONES office.