Removing Barriers Blog

CUNA Weighs in on NCUA’s Annual Reg Review
Posted May 30, 2019 by Chandler Schuette

Today, CUNA sent a comprehensive letter to NCUA detailing a number of issues the agency should address as part of its annual, one-third regulatory review. We support the agency’s policy of continually reviewing its regulations to determine whether they should be updated, clarified, simplified, or eliminated. Further, we appreciate the recent work of the NCUA’s Regulatory Reform Task Force, which released its second and final report in December 2018.

This year’s review includes part 700 through 710 of NCUA’s rules and regulations. While we addressed most parts up for review, our comments focused on: section 701.1 (FCU Chartering and Field of Membership); section 701.2 (FCU Bylaws); section 701.34 (Low-income Credit Unions); and part 704 (Corporate Credit Unions).

In addition, we reiterated—as we have in most previous reg review letters—our concern with NCUA’s process for identifying rules and soliciting comments. Since the notice of the regulatory review is not required to comply with the Administrative Procedure Act, and is therefore not published in the Federal Register, potential commenters may be unaware of its issuance. To ensure adequate input is received, we ask NCUA to consider ways to better highlight its request for comments on the regulatory review, including by announcing the review during a board meeting.