ARLINGTON, Va.–The trade group representing state regulators has told NCUA it generally supports the agency’s proposed changes to rules on supervisory committee audits, but it also has some specific objections.
In a comment letter on NCUA’s rule Part 715, Supervisory Committee Audits and Verifications, NASCUS objected to the proposed inclusion of BSA or pay benefits in the Appendix A audit requirements. NASCUS also strongly recommended in its letter the agency consider further refining the organization of its rules and regulations to clarify which provisions of Part 715 apply to state-chartered credit unions and which do not.
“NASCUS supports retiring the NCUA Supervisory Committee Guide and replacing that audit option with the option to obtain an audit that meets stipulated requirements to be included in a new Appendix A to Part 715,” NASCUS Executive Vice President and General Counsel Brian Knight wrote. “We agree this change would simplify the compliance burden for credit unions utilizing this audit option.”
‘Not Convinced’
On whether BSA or pay and benefits should be included as mandatory Appendix A audit requirements, Knight wrote, “NASCUS is not convinced that adding these subject areas to the Appendix A audit requirements would produce enough supervisory value to justify the increased cost for credit unions.”
NASCUS also called on NCUA to reorganize its rules and regulations to clarify which rules apply to federally insured state-chartered credit unions (FISCUs) and which rules are federal credit union only requirements.
Specifically, NASCUS recommended NCUA incorporate FISCU specific audit requirements in its entirety in Part 741, with the letter stating, “This would allow credit unions, and examiners, to have a consolidated reference of applicable rules and regulations.”