ARLINGTON, Va.—NAFCU has sent a letter to NCUA expressing appreciation for the agency’s participation in the Economic Growth and Regulatory Paperwork Act (EGRPRA) review, but said the bigger issue remains that “the regulatory pendulum post-crisis has swung too far towards an environment of overregulation that threatens to stifle economic growth.”
The letter, authored by NAFCU Director of Regulatory Affairs Alicia Nealon, urges NCUA to look for ways under its purview to provide regulatory relief for credit unions.
Specifically addressing the agency’s requests for comments on areas of regulations within the categories of “Agency Programs,” “Capital,” and “Consumer Protection,” Nealon said that “NAFCU believes obtaining membership in the Central Liquidity Facility (CLF) is unnecessarily burdensome” and that a legislative solution is necessary to relax the current CLF membership standards.
On NCUA’s capital planning and stress-testing, Nealon says in the letter that “while NAFCU recognizes that the health of the National Credit Union Share Insurance Fund (NCUSIF) is essential for the credit union industry, and stress testing and capital planning are important tools for credit unions to assist in proper management, we believe that the 2014 capital planning and stress testing rule does little to enhance the security of the NCUSIF.”
With regards to consumer protection, Nealon says NAFCU recommends NCUA change the letter “x” to the letter “v” in Appendix C’s Official Staff Interpretations since it does not reflect the current Section 707.2.