WASHINGTON—CUNA is calling on new NCUA Chairman Todd Harper to quickly review several rulemakings.
“We appreciate your transparency in identifying your top policy priorities: capital and liquidity, consumer financial protection, cybersecurity, and diversity, equity, and economic inclusion,” wrote CUNA President/CEO Jim Nussle in a letter to the agency. “These priorities are also of utmost importance to CUNA, our member credit unions, and their consumer-members. We are excited to work with you and the agency in advancing such laudable objectives.”
CUNA is strongly urging NCUA to issue an interim final rule, consistent with one issued by banking agencies, that would use asset data as of Dec. 31, 2019 to determine applicability of certain asset-based regulatory thresholds.
“Due to the COVID-19 pandemic and balance sheet growth as a result of new COVID-related policies, there are credit unions that could be subject to additional regulatory or reporting requirements in 2021 because they are temporarily pushed over an asset-size threshold for compliance,” the letter states.
The issue was also discussed during the most recent NCUA board meeting, conducted prior to Harper being elevated to chairman.
The Rulemakings
CUNA called on NCUA to quickly review pending rulemakings issued at the December and January board meetings, including:
- Credit Union Service Organizations: The proposal would expand the list of permissible activities and services for CUSOs to include originating any type of loan that a federal credit union (FCU) may originate and has CUNA support.
- Field of Membership Shared Facility Requirements: The proposal would amend the chartering and field of membership (FOM) rules to modernize requirements related to service facilities for multiple common bond FCUs
- Mortgage Servicing Rights: The proposal would amend the NCUA’s investment regulation to permit FCUs to purchase mortgage servicing rights from other federally-insured credit unions under certain conditions
- Overdraft Policy: The new rule replaces the 45-day limit within which a member must rectify an overdraft with a more flexible approach, permitting such action be taken within a reasonable period of time
- CAMELS Rating System: The proposal would add an “S” (Sensitivity to Market Risk) component to the existing CAMEL rating system and redefine the “L” (Liquidity Risk) component
- Risk-Based Net Worth, Complex Threshold: The would temporarily raise the asset threshold for defining a credit union as “complex” for purposes of being subject to any risk-based net worth requirement