WASHINGTON— America’s Credit Unions and Defense Credit Union Council have each submitted comments to the National Credit Union Administration in response to six deregulatory proposals, largely supporting efforts to streamline rules while differing on at least one governance-related change.
Both organizations said the proposals are part of the NCUA’s ongoing Deregulation Project aimed at eliminating duplicative or outdated requirements.
Refund of Interest
- America’s Credit Unions: Supported rescinding the regulation as duplicative of the Federal Credit Union Act but urged the NCUA to preserve flexibility for boards to vary interest refunds by loan type. The ACU letter can be found here.
- DCUC: Supported eliminating the rule, calling it redundant because the authority already exists in statute and noting removal would not affect safety and soundness.
Compensation in Connection with Loans
- America’s Credit Unions: Backed modernization of compensation rules and called for clearer definitions of safety-and-soundness terms, consistent examiner treatment, and confirmation that lending metrics can be used within broader performance frameworks. The ACU letter can be found here.
- DCUC: Supported a more flexible, principles-based approach allowing incentive compensation tied to overall financial performance, including for senior management, saying it would help attract and retain talent.
Credit Union Service Contracts
- America’s Credit Unions: Supported deleting the regulation as duplicative and asked the NCUA to clarify authority for credit unions to act as representatives in shared service agreements. The ACU letter can be found here.
- DCUC: Also supported removing the rule, stating it merely restates statutory authority and that requiring written agreements reflects standard business practice, not a need for regulation.
Post-Election Training for Board Members
- America’s Credit Unions: Supported eliminating the requirement that new directors achieve financial literacy within six months, calling it overly prescriptive and noting existing governance frameworks address risk. The ACU letter can be found here.
- DCUC: Opposed removing the requirement, warning it could weaken board oversight, reduce financial literacy, and increase risk in areas such as compliance and audit response.
Purchase, Sale, and Pledge of Eligible Obligations
- America’s Credit Unions: Supported removing prescriptive policy requirements and duplicative provisions already covered elsewhere. The ACU letter can be found here.
- DCUC: Supported shifting to a principles-based approach, arguing detailed requirements may not fit all credit unions and are better handled through supervisory guidance.
Statutory Liens
- America’s Credit Unions: Supported removing a preemption-related definition it said is redundant and potentially confusing. The ACU letter can be found here.
- DCUC: Supported deleting the same definition, saying it does not provide meaningful clarity and is unnecessary within the broader legal framework.
DCUC said its comments reflect support for “balanced, accountable deregulation,” emphasizing reduced burden alongside maintaining governance and member protections, while America’s Credit Unions’ letters similarly backed modernization paired with clarity and consistency in supervision.
