Removing Barriers Blog

CUNA calls on NCUA Revise Aspects of Rulemaking on Combination Transactions
Posted March 25, 2020 by dyi

Today, CUNA filed a comment letter with the NCUA regarding its proposed rulemaking on combination transactions with non-credit unions. The NCUA Board issued a proposal to adopt new Subpart D of Part 708a intended to clarify and make transparent the procedures and requirements related to combination transactions. Combination transactions include those where a federally insured credit union proposes to assume liabilities from a non-credit union, including a bank; they also include a credit union’s merger or consolidation with a non-credit union entity.

The proposal essentially codifies current requirements and practices related to combination transactions with non-credit unions. While the proposal does not introduce much that is new, CUNA believes codifying and centralizing the existing requirements will aid credit unions pursuing such transactions. While we support the majority of the proposed rule, there are a few aspects that are not statutorily required (or required elsewhere in the NCUA’s regulations), several of which may be problematic. So, we provide comments and proposed revisions to those sections. 

Comments are due to the NCUA on this proposed rule on or before Monday, March 30th.