Today, CUNA filed a comment letter in response to the agency’s RFC on the operating fee and overhead transfer rate methodologies. We emphasized our position that “It is not our intent, nor should it be that of the NCUA, to benefit a federal credit union (FCU) over a federally insured state-chartered credit union (FISCU) or a FISCU over a FCU. . . . Our goal is to ensure a fair distribution of the charges for the supervision of credit unions—consistent with the FCU Act—for all credit unions regardless of charter type.”

We provided input on several aspects of the RFC, including increasing the operating fee exemption for credit unions below $10 million in assets. In addition, we offered suggestions on how the agency can improve the annual diversity self-assessment, which we stress must remain voluntary.