CUNA remains convinced that this IRR rule is regulatory overkill and only bloats the already hefty regulatory burden on credit unions. While the agency asserts that 55 percent of all credit unions will be unaffected, the fact is that the 45 percent subject to the rule count more than 90 percent of all credit union members, meaning that the rule affects the vast majority of credit union operations. Further, the agency still has not provided sufficient evidence that it is necessary for the rule to link compliance with its requirements for federal credit union savings insurance coverage (through the NCUSIF). Comments by Chairman Matz and senior staff at today’s meeting are useful clarifications. Those are: That guidance accompanying the rule is not to be used by examiners as a compliance checklist and that the agency does not intend to remove a credit union’s NCUSIF coverage over this rule. The delayed compliance date, to Sept. 30, is also a beneficial clarification. CUNA will be pushing NCUA to ensure these clarifications are followed.