Removing Barriers Blog

CUNA Sends Letter Opposing Warren Amendment to CISA
Posted August 05, 2015 by CUNA Advocacy

On August 5, 2015, CUNA sent a letter opposing a possible amendment to the Cybersecurity Information Sharing Act (CISA) that would grant NCUA direct oversight authority over third-party vendors that many credit unions use to deliver high quality, cost effective services to their members.  The amendment, offered by Senator Elizabeth Warren (D-MA), would have made third-party vendors “subject to regulation and examination by the [NCUA] Board to the same extent as if … services were being performed by [an] insured credit union itself.”

CUNA’s opposition is threefold:

1.       Expansion of NCUA authority to third-party vendors is unnecessary because credit unions are already supervised for due diligence in third-party vendor relationships during their regular examinations.

2.       This unnecessary expansion would make it more expensive for credit unions to serve their members, as third-party service providers will ultimately pass along the increased cost of additional NCUA supervision.

3.       The substance of the amendment extends beyond the scope of the CISA bill, which is narrowly tailored to promote voluntary information sharing regarding cybersecurity threats among private sector actors and government agencies.

CUNA continues to monitor attempts to materially change the scope or substance of NCUA’s supervisory authority, whether of credit unions themselves or the third-party vendors upon which they rely to enhance the level of service they are able to provide to their members.