Removing Barriers Blog

Comment Letters Filed w/NCUA re Interim Final Rules
Posted May 24, 2021 by CUNA Advocacy

Today, we filed letters with NCUA on two separate interim final rules.

Central Liquidity Facility IFR

We support an IFR that updated NCUA’s regulations to reflect extensions of CARES Act provisions made by the Consolidated Appropriations Act. These temporary flexibilities to the CLF have been helpful.

We support statutory changes to make these changes to the CLF permanent. “We believe it is important to ensure such changes are in place prior to any future stress on the industry to avoid scrambling to make such (temporary) changes during a time of crisis.”

Asset Thresholds IFR

We support an IFR regarding the measurement of assets for determining applicability of certain regulatory requirements. To mitigate transition costs on credit unions related to the pandemic, the IFR permits credit unions to use asset data as of March 31, 2020, in order to determine the applicability of certain regulatory asset thresholds during calendar years 2021 and 2022. Specifically, the IFR allows a credit union to use March 31, 2020, financial data when determining whether it is subject to capital planning and stress testing requirements and supervision from ONES.

Complying with these more stringent regulatory standards would impose additional transition and compliance costs on credit unions that otherwise may not have become subject to these requirements at this time. Given the rapid and unexpected nature of credit union asset growth in 2020, many credit unions are unlikely to have planned for these transition costs.

While we appreciate the relief provided by the IFR, we urge the NCUA to extend its application, permitting credit unions to use March 31, 2020, asset data for purposes of the March 2022 measurement date. Doing so would potentially benefit several additional credit unions, representing millions of memberships.