WASHINGTON — The Defense Credit Union Council is urging the National Credit Union Administration to adopt regulatory changes that reduce compliance burdens for credit unions while cautioning against eliminating provisions it says continue to provide value.
In two comment letters submitted to the NCUA, the Defense Credit Union Council (DCUC) expressed support for the agency’s proposal to increase asset thresholds under the Depository Institution Management Interlocks Act (DIMIA), while raising concerns over a separate proposal to reorganize the agency’s share insurance regulations. DCUC summarized its positions in a news release.
On the DIMIA proposal, DCUC endorsed the NCUA’s plan to increase the “major assets prohibition” threshold to $10 billion, arguing the current thresholds, established in 1996, no longer reflect the size and growth of federally insured financial institutions. The organization said updating the thresholds would better target restrictions intended for the nation’s largest institutions while reducing unnecessary regulatory burdens on smaller credit unions.
Support for New Threshold
DCUC also backed the agency’s proposal to establish a single $10 billion threshold for both institutions involved in a management interlock, saying it would create a more consistent and predictable regulatory framework aligned with approaches used by other federal financial regulators.
However, the organization opposed the NCUA’s proposal to eliminate the rebuttable presumption that management interlocks involving institutions controlled or managed by women or minority groups do not substantially lessen competition.
DCUC said the agency had not demonstrated that removing the provision would improve supervision or reduce regulatory burden and argued that retaining it would preserve regulatory certainty while imposing little administrative burden.
Letter on Share Insurance Revisions
In a separate comment letter addressing proposed revisions to the NCUA’s share insurance regulations, DCUC said it supports the agency’s broader deregulatory initiative but questioned whether the specific proposal would achieve meaningful regulatory relief.
The organization said the proposal would eliminate a centralized section containing cross-references to other applicable NCUA regulations. While that could reduce the amount of regulatory text credit unions must review, DCUC argued the existing cross-references serve as an important compliance aid by helping federally insured credit unions identify related regulatory requirements and understand how the agency’s regulatory framework fits together.
Instead, DCUC encouraged the NCUA to focus on reforms that produce measurable reductions in operational complexity and compliance costs. The group also recommended supplementing the agency’s formal rulemaking process with stakeholder roundtables and listening sessions to identify regulations that impose unnecessary burdens on credit unions.
The CU Daily had coverage of America’s Credit Unions’ comment letters on the same issues here.
