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.