WASHINGTON–CUNA is objecting to many of the proposals NCUA has made regarding disclosure to members in voluntary mergers.
It raised its objections in one of three comment letters to the agency; its other letters addressed appeals for material supervisory determinations and appeals procedures.
In the case of the voluntary merger rule, CUNA’s letter requests that NCUA make several substantive changes. Specifically, CUNA said it does not support additional disclosures “when the disclosures do little to help credit union members decide whether to approve a merger or can slow or stop mergers.” The trade group said it also does not support merger notice periods that do not line up with current NCUA requirements or what it called the “onerous member to member communication requirement.”
CUNA added that it placed particular emphasis on its position in the letter that credit unions “do not want updates to the merger rule to increase credit unions’ regulatory burden.”
Separately, CUNA also filed comment letters supporting NCUA proposal Part 746 – appeals for supervisory determinations and appeals process.
“Both of these proposals would expand and clarify a multitude of NCUA appeals processes and credit union appeals rights to NCUA staff, the supervisory review committee (SRC), and the board,” CUNA said.
The addition of Subpart A to Part 746, which amends procedures for appealing material supervisory determinations to the NCUA Supervisory Review Committee (SRC), would expand the number of supervisory determinations appealable to the SRC and provide credit unions with the opportunity for additional review by the director of the Office of Examinations and Insurance, CUNA said.
CUNA noted the addition of Subpart B to Part 746 would adopt procedures to govern appeals to the NCUA board that apply to agency regulations that currently have their own embedded appeals provisions. The procedures would apply in cases in which a decision rendered by a regional director or other program office director is subject to appeal to the board.
In a statement, CUNA said it will continue to work with the NCUA to communicate credit union concerns with the proposed merger rule, to eliminate or reduce any regulatory burden that could result from an updated rule.