ALEXANDRIA, Va.—With one third of NCUA’s regulations up for their annual review, NAFCU has sent a letter to the agency offering its input on where it wants to see action taken.
NCUA is reviewing Parts 711-747 of its regulations.
In its letter, NAFCU Senior Regulatory Affairs Counsel James Akin outlined several recommendations and urged the agency to carefully consider the requests and “act swiftly to issue proposed rules or take other action as appropriate.” However, Akin noted that “certain aspects may require congressional action to achieve full modernization with industry standards and practices.”
“In such instances, NAFCU urges the NCUA to coordinate with members of Congress and support legislation to update the Federal Credit Union Act,” wrote Akin. “[…] NAFCU looks forward to future opportunities to work with the NCUA to achieve modernization of the regulations affecting America’s credit unions.”
New Requests Made
Akin made new requests to the agency, including urging NCUA to add the cashing of "on-us" checks and the use of coin sorter machines in credit union lobbies as preapproved activities necessary to carry on the business of the credit union in Section 721.3.
NAFCU further urged NCUA to clarify that the sale of stored value products to nonmembers within the field of membership be considered as a marketing activity.
In addition, Akin requested new guidance from the NCUA related to credit unions assessing the validity of a change of address, as well as credit union boards’ approval and review of insurance coverage and an impact study on the NCUA’s final rule on obtaining fidelity bonds.
Other Points Raised
The letter also requested:
- The raising the current threshold for net aggregate business loans excluded from the definition of a commercial loan from its current threshold $50,000 to $250,000
- Clarification on various issues related to credit union service organizations, including credit unions to have direct investment powers in fintech
- Requesting enhancements to the Central Liquidity Facility made by the CARES Act be made permanent
- Authorization for credit unions to use automated valuation models (AVMs) when conducting pre-funding reviews of appraisals
- Raising the member business lending (MBL) cap to ensure credit unions can effectively lend to small businesses in their communities
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