MARLBOROUGH, Mass.–The Cooperative Credit Union Association has submitted six additional comment letters to NCUA as part of Round Six of the agency’s ongoing Deregulation Project.
According to the association, its comments “emphasize the importance of reducing unnecessary regulatory burden while preserving critical member protections and maintaining the cooperative structure that sets credit unions apart.”
The Comment Letters
The comments include:
- CU Service Contracts: The CCUA said it supports the board’s proposal to delete the Section 701.26 Credit Union Service Contracts regulation as a superfluous compliance burden.
- Statutory Leins: Support was expressed for the proposal to delete the Section 701.39 Statutory Liens definition as it creates unnecessary compliance burden and interpretive complexity for credit unions.
- CU Interest Refunds: The CCUA supports the proposal to delete the Section 701.24 Refund of Interest regulation as it is redundant with the Federal Credit Union Act and creates unnecessary regulatory complexity for credit unions.
- Eligible Obligations: The association said it supports the proposal to amend Section 701.23 on Purchase, Sale, and Pledge of Eligible Obligations as it streamlines regulatory requirements, reduces compliance and paperwork burdens, and provides credit unions with greater flexibility in managing their balance sheets.
- Loan Compensation: Support was expressed for an amendment to Section 701.21(c)(8) as it clarifies performance metrics, reduces regulatory burden, and gives credit unions greater flexibility in executive compensation design.
- BOD Training: The CCUA said it supports the proposal to remove paragraph (b)(3) of Section 701.4 as it eliminates redundancy, reduces regulatory burden, and preserves flexibility for credit unions in board composition and governance.
