WASHINGTON–America’s Credit Unions has submitted two comment letters in response to NCUA’s ongoing Deregulation Project, bringing to four the proposals on which the trade group has filed comment.
Its comment letters include:
Chartering and Field of Membership (FOM) for Federal Credit Unions (FCUs) — IRPS 08-2, which eliminates Interpretive Ruling and Policy Statement (IRPS) 08-2. America’s Credit Unions wrote that it would aid FCUs by pointing them to a single, definitive regulatory text: Appendix B to Part 701. The proposed rescission will make it easier for FCUs to “understand and cite a single, controlling authority, reduce ambiguity, and ensure that outdated rules do not create confusion for credit unions researching FOM regulations,” ACU said.
Chartering and FOM for FCUs – IRPS 10-1, which would rescind IRPS 10-1. America’s Credit Unions expressed support, noting that NCUA’s FOM and chartering rules are currently codified in Appendix B to Part 701 and reflect the agency’s most current interpretations of the Federal Credit Union Act’s (FCU Act) provisions. Now, all current information pertaining to FOM and chartering rules is now consolidated in the Chartering Manual, America’s Credit Unions noted.
Nondiscrimination Requirements, which proposes to remove a regulation that summarizes Fair Housing Act (FHA) prohibitions on discrimination related to real estate related loans, appraisals, and advertising. Americas Credit Unions said the proposal would “ease regulatory burdens for FCUs by removing a redundant and outdated regulation that risks creating inconsistencies with other federal laws.” The trade group further stated that more comprehensive federal laws already exist in this area, specifically the FHA and Equal Credit Opportunity Act, along with their implementing regulations, such as the CFPB’s Regulation B.
Corporate Credit Unions, which proposes to remove IRPS 11-02, which addresses chartering corporate credit unions, due to its redundancy. In its letter, America’s Credit Unions suggested its removal would eliminate potential confusion and reduce regulatory burden for FCUs by limiting the number of sources that they must check to ensure compliance with laws and regulations on chartering corporate credit unions.
