DCUC Urges NCUA to Keep ‘Conspicuous’ Disclosure Rules in Place on CU Mergers into Banks; Sends Letters to Hill

WASHINGTON — The Defense Credit Union Council is urging the National Credit Union Administration to preserve key member disclosure requirements while supporting portions of a proposed rule intended to streamline regulations governing mergers of federally insured credit unions into banks.

Separately, DCUC has also sent a number of new comment letters to Capitol Hill. The CU Daily had coverage of comment filed by America’s Creit Unions and the Cooperative Credit Union Association on the NCUA proposal on CUs merging into banks here.

In a comment letter to the NCUA, the Defense Credit Union Council (DCUC) said it supports the agency’s efforts to eliminate outdated and unnecessary regulatory requirements, but stressed that member transparency and board accountability should remain central to transactions that fundamentally alter a credit union’s ownership structure.

According to DCUC, the organization supports several elements of the proposal, including eliminating the requirement that merger notices be published in newspapers of general circulation, removing outdated formatting requirements and relocating non-binding voting guidance outside of the agency’s regulations.

Retain ‘Clear & Conspicuous’

However, DCUC urged the NCUA to retain the existing definition of “clear and conspicuous,” stating that the standard provides objective criteria that help credit unions meet member disclosure requirements.

The trade group also recommended preserving disclosure requirements that explain how a credit union’s board selected a merger partner and negotiated a merger agreement. DCUC said such information is important in helping members and regulators determine whether a proposed transaction is in the best interests of the membership.

The NCUA proposal is part of the agency’s broader effort to review and update regulations governing credit union mergers into banks.

In its letter, DCUC said it remains committed to working with the NCUA on regulatory reforms that reduce unnecessary compliance burdens while protecting credit union members and strengthening the cooperative financial system.

Comment Letters Sent

Meanwhile, DCUC has submitted a series of letters this week on issues ranging from military financial readiness and the future of payments to credit union regulation, community development funding and consumer affordability.

The trade group, which represents more than 200 defense credit unions serving more than 40 million members worldwide, outlined policy recommendations in correspondence sent to congressional committees and the Treasury Department. DCUC said the letters were intended to provide lawmakers and regulators with the credit union perspective ahead of several key hearings and nomination proceedings.

Defense Department Nominee

Ahead of a confirmation hearing before the Senate Armed Services Committee, DCUC urged lawmakersto examine how the Department of Defense could strengthen military financial readiness during consideration of the nomination of Jules W. Hurst III for under secretary of defense (comptroller) and chief financial officer.

According to DCUC, financial stress among servicemembers can affect mission readiness, force resilience, recruitment, retention, security clearances and family stability.

“We encourage the Committee to also explore how Mr. Hurst and the Department can further strengthen military financial readiness and deepen collaboration with the more than 200 defense credit unions serving military communities around the world,” DCUC President and CEO Anthony Hernandez said in a statement released by the organization.

Future of Payments

Prior to a House Financial Services Committee hearing on the future of payments, DCUC called on lawmakers to preserve what it described as a secure, competitive and reliable payments system.

In its letter, the organization said policymakers should focus on:

  • Payments innovation.
  • Cybersecurity protections.
  • Fraud prevention.
  • Regulatory parity among financial institutions.
  • Consumer protection.
  • Competition within the payments ecosystem.

DCUC Chief Advocacy Officer Jason Stverak said military families often depend on uninterrupted access to payment services as they relocate, deploy overseas and move across state lines.

Hernandez said credit unions play a key role in maintaining trust in the payments system by investing in cybersecurity, absorbing fraud losses and protecting consumers when problems occur.

NCUA Board Nomination

DCUC also submitted comments to the Senate Banking Committee supporting the nomination of John Crews to serve on the National Credit Union Administration board.

In its letter, the organization highlighted a number of regulatory priorities it believes should be addressed during the confirmation process.

Among its primary recommendations, DCUC called for:

  • Continued stewardship of the National Credit Union Share Insurance Fund within the framework established by Congress.
  • Responsible modernization of field-of-membership rules.
  • Regulation tailored to a credit union’s size, complexity and risk profile.

The organization also urged discussion of several additional issues, including:

  • Examination consistency and transparency.
  • Modernization of the CAMELS rating system.
  • Preservation of federal preemption where appropriate.
  • Strengthening the Central Liquidity Facility.
  • Responsible financial innovation.
  • Cybersecurity and third-party vendor oversight.
  • Military financial readiness.
  • Governance modernization.
  • Continued credit union access to military installations.
  • Expanded lending opportunities for veteran-owned small businesses.

DCUC said effective regulation depends on transparency, stakeholder engagement and consideration of diverse viewpoints.

Treasury and CDFI Funding

In a separate letter to Treasury Secretary Scott Bessent, Hernandez expressed concern over reported delays and uncertainty surrounding awards and disbursements from the Community Development Financial Institutions Fund.

The organization said uncertainty over funding timelines and administrative capacity is creating challenges for institutions serving military, rural and underserved communities.

In its comment, DCUC urged Treasury to:

  • Ensure timely distribution of congressionally appropriated CDFI funds.
  • Increase transparency regarding award timelines.
  • Maintain sufficient staffing and operational resources.
  • Consult stakeholders on future policy or procedural changes.
  • Continue supporting CDFIs’ role in financial inclusion, affordable housing and small-business development.

Hernandez said the CDFI Fund has historically received bipartisan support because it leverages federal and private capital to expand economic opportunity in underserved communities, including military-connected populations.

Affordability Agenda

Ahead of a Senate Banking Committee hearing titled “The Affordability Agenda: Addressing the Cost-of-Living Crisis Facing American Families,” DCUC outlined what it described as market-based solutions aimed at expanding access to affordable financial services.

The organization’s recommendations included:

  • Advancing the Veterans Member Business Loan Act.
  • Modernizing field-of-membership authorities.
  • Expanding affordable housing finance options.
  • Removing statutory restrictions that limit credit unions’ ability to serve consumers.

DCUC said rising housing costs, inflation, insurance expenses and other household costs continue to place pressure on military families, veterans and working Americans.

“For military families, veterans, and working Americans, affordability is not simply an economic talking point,” Stverak wrote in comments submitted to the committee. “It is the reality of whether they can purchase a home, finance a vehicle, launch a small business, save for retirement, or navigate unexpected financial challenges.”

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