Removing Barriers Blog

Fixed Assets Comment Letter Filed With NCUA
Posted June 24, 2016 by CUNA Advocacy

This week we filed a comment letter supporting NCUA’s latest fixed assets proposed rule.  The proposed rule would update NCUA’s federal credit union occupancy, planning and disposal of acquired and abandoned premises and incidental powers regulations to add flexibility in the ownership and use of buildings and land for federal credit unions. 

Specifically, the proposed rule would eliminate the current requirement that credit unions eventually fully occupy or use land and building.  The full occupancy requirement would be replaced by a requirement that FCUs partially occupy building or premises within six years.  The proposal defines partial occupancy as the use of at least 50% of a building or premises.  The rule also would make changes to the incidental requirements that allow FCUs to lease excess space without the requirement to eventually plan for the use of excess space. 

We have long advocated for NCUA to make these changes, since they would add additional flexibility for FCUs to own and use fixed assets. We feel that NCUA could easily add more flexibility to the fixed assets requirements by increasing the partial occupancy requirement to 10 years, or eliminating it altogether by basing fixed assets use limits on safety and soundness.  We also asked for NCUA to clarify the waiver process for occupancy and use requirements.  We suggested that the waivers be granted automatically unless there are safety and soundness issues.   

NCUA should be commended for continuing to update the fixed assets requirements over the past several years.