WASHINGTON–In a 14-page comment letter, America’s Credit Unions is offering numerous recommendations to NCUA on its strategic plan, budget, and restructuring.
The letter, signed by Regulatory Advocacy Senior Counsel Luke Martone, was sent in response to the agency’s request for input.
According to America’s Credit Unions’ synopsis of its letter, its recommendations include:
Strategic Plan
- Refine the agency’s mission and vision statement to better reflect a forward-looking, innovation-friendly, and access-driven supervisory approach that empowers credit unions to serve their members more effectively while maintaining safety and soundness
- Add a fourth strategic goal focused on supporting credit unions into the future as CUs compete with fintechs and banks.
Agency Reorganization
- Improve the examination process by focusing examiner time and agency resources on high-risk or complex credit unions, reducing regulatory burden on well-managed credit unions and increasing use of offsite analytics for low- and moderate-risk credit unions
- Enhance stakeholder engagement by better incorporating credit union feedback into policy development and supervisory priorities, which traditionally are established without outside input
- Pursue continuous improvement, including performance tracking. This could involve setting clear performance standards for agency processes, such as exam turnaround time and timeliness of staff responses to credit union inquiries
Budget
- Address the agency’s expanding budget that has come as the number of federally insured credit unions declined;
- Renew its commitment to reducing travel-related expenses by expanding the use of offsite and hybrid examinations, when appropriate given a credit union’s risk profile and operational complexity;
- Exercise restraint with departmental budgets—particularly considering industry consolidation; and
- Make explicit the calculation of cash requirements in the Operating Budget.
The full letter can be found here.
