Today, CUNA filed a comment letter in support of NCUA’s proposal to amend its regulation governing assessment of the annual operating fee to FCUs. The proposal would primarily:

1. For purposes of calculating the annual operating fee, it would amend the current rule to exclude from total assets any loan an FCU reports under the SBA’s Paycheck Protection Program (PPP) or similar future programs approved for exclusion by NCUA.
2. It would also amend the period used for the calculation of an FCU’s total assets. Currently, total assets are calculated using the FCU’s December 31^st Call Report of the preceding year. Under the proposed rule, total assets would be calculated as the average total assets reported on the FCU’s previous four Call Reports.

We support the proposed exclusion of PPP loans from an FCU’s total assets for purposes of calculating its operating fee. This change should help ensure that FCUs interested in making PPP loans do not bear greater financial burdens for doing so.

We also support the proposed change to a four-quarter average of reported assets in calculating the operating fee. We agree with the agency that this change will address seasonality and provide greater certainty of upcoming operating fees.