WASHINGTON–America’s Credit Unions has filed a comment letter with NCUA in which it identifies areas it said the agency can reduce regulatory burdens and address outdated, unnecessary, and unduly burdensome regulations.
The letter, signed by Regulatory Advocacy Senior Counsel Luke Martone, was sent in response to comment being sought by NCUA as part of the Economic Growth and Regulatory Paperwork Reduction Act, which requires federal banking agencies to conduct reviews every 10 years of regulations that can be eliminated or streamlined.
As the CU Daily reported here, this year’s review covers agency programs, capital, and consumer protection categories of regulations.
Areas of Recommendation
America’s Credit Unions said its has made recommendations in the following areas:
- Community Development Revolving Loan Fund: “Streamline the burdensome application process and seek regular CU input to better align funding with needs.”
- Central Liquidity Facility: “Shorten approval timelines, reinforce that CLF use carries no stigma, and support restoring CARES Act enhancements (corporate credit union agent authority) permanently.”
- Low-Income designation: “Expand qualification methods, increase transparency, and consider lowering the income threshold.”
- Capital adequacy: Americas Credit Unions noted it reiterated much of what was included in a recent letter sent to the NCUA, that the agency should modernize capital standards by lowering the CCULR, ease subordinated debt issuance, adjust thresholds, and tailoring stress tests.
- Nondiscrimination: “Remove or revise credit union-only restrictions and overly broad appraisal liability standards inconsistent with the Fair Housing Act.”
- Truth in Savings: “Update disclosure rules for digital channels and clarify fee disclosures.”
- Advertising and insured status: Modernize signage and disclosure rules for digital/mobile platforms and social media.
- Member inspection rights: “Preserve federal framework but control abuse by raising petition thresholds, limiting scope, and expanding exemptions.”
