WASHINGTON–CUNA is calling on NCUA to continue its regulatory relief agenda and has made recommendations for where it believes the agency can go further.
In a letter to the agency by Monique Michel, senior director, advocacy and counsel, the trade group said it applauds NCUA for the steps it has taken to date to reduce burdensome regulations, adding the “cost burden is especially egregious for smaller financial institutions.”
Among the issues addressed in the CUNA letter:
Loans to Members and Lines of Credit to Members
CUNA said it supports regulations that provide credit unions flexibility in loans offered, collateral to secure loans, terms, collections, and underwriting. “From a compliance practitioner standpoint, co-location of all loan maturity limitations will be useful. Codification of the legal opinion that clarifies a lending action not subject to the Generally Accepted Accounting Principles (GAAP) standard for a ‘new loan’ is therefore not subject to the maturity limits will provide clarity and consistency across examination regions,” CUNA said.
It also expressed support for longer maturity limits for 1-4 family real estate loans and other similar housing loans.
Loans to Members and Lines of Credit to Members: Single borrower and group of associated borrowers
“Again, for compliance purposes, repositioning the references for limits on single borrower and group of associated borrowers into one statutory location will provide consistency, which CUNA supports,” the letter states.
Loans to Members and Lines of Credit to Members: Third-party servicing of indirect vehicle loans
CUNA said it supports the elimination of portfolio limits and the related waiver provision. “In development of a new comprehensive third-party due diligence regulation addressing the minimum expectations for credit unions using and third-party loan servicers, servicing standards should apply uniformly and not impose any new or additional regulatory burdens.”
Appendix B to Part 701—Federal Credit Union Bylaws
Any Advanced Notice of Proposed Rulemaking (ANPR) and subsequent working group to address updating bylaws should not impose new and additional regulatory compliance or reporting burdens on credit unions. Indeed, bylaws should be optional, with credit unions permitted to use their own bylaws, CUNA said.
The CUNA letter also addresses Appendix A to Part 701—Chartering and Field of Membership Manual; Appendix B to Part 701—Emergency Mergers; Appendix B to Part 701—Capital Adequacy; Capital Adequacy—Risk-Based Capital; Part 704—Corporate Credit Unions; Part 704—Fidelity Bond and Insurance Coverage, and more than a dozen other issues.
A complete copy of the CUNA letter to NCUA can be found in CUToday.info’s The Gov here.