ARLINGTON, Va.—In a comment letter to NCUA, NAFCU told the agency that federal credit union bylaws need streamlining and improving to provide CUs greater “flexibility.”
"NAFCU continues to hear our members request that NCUA explore provisions of the bylaws that could be enhanced, streamlined and improved in order to provide additional flexibility to FCUs," wrote Senior Regulatory Affairs Counsel Michael Emancipator, urging NCUA to issue a proposed rule or advanced notice of proposed rulemaking to continue this work.
He recognized NAFCU's and its members' efforts to provide ideas for improvements to the bylaws. Emancipator also noted the agency's working group established in 2014 to study and develop suggestions for improvements.
"Accordingly, as part of the agency’s ongoing continual quality improvement initiative and related to its current efforts to modernize field-of-membership rules, NAFCU believes now is an appropriate time for the agency to revisit improvement of FCU bylaws," he said.