Today, CUNA
filed a comment letter
with NCUA in support of its proposed rule intended to update, clarify, and
simplify provisions of its regulations pertaining to corporate credit unions.
The proposal would achieve this by:
- Permitting
a corporate credit union to make a minimal investment in a CUSO without
the CUSO being classified as a corporate CUSO and subject to heightened
NCUA oversight;
- Expanding
the categories of senior staff positions at member credit unions eligible
to serve on a corporate credit union’s board;
- Removing
the experience and independence requirement for a corporate credit union’s
enterprise risk management expert;
- Clarifying
the treatment of an investment in a subordinated debt instrument of a
natural person credit union; and
- Codifying
the current list of permissible activities for a corporate CUSO.
While we are
generally supportive of the proposed rule, as discussed in our letter, we noted
concern with some of the proposed changes.
Since corporate credit unions are a vital
component of the credit union system, providing critical services and functions
necessary to the effective and efficient operation of natural person credit
unions, we used the opportunity to ask the agency to pursue additional changes
outside this rulemaking aimed at reducing unnecessary regulatory burden on
corporate credit unions.