MARLBOROUGH, Mass.–The Cooperative Credit Union Association has submitted four letters to NCUA to several proposals that are part of its Deregulation Project. The letters, developed with credit union feedback, can be found on the CCUA website and are linked in the titles below, the organization said.
The Feedback
Rescinding IRPS 11-02 on Corporate Credit Union Chartering: The CCUA said it supports rescinding this ruling because it is redundant, as its contents have already been incorporated into the Corporate Federal Credit Union Chartering Manual. The letter argues that moving away from binding rules in favor of manual guidance is appropriate given the board’s broad discretion and the fact that no new corporate credit union has been chartered in over a decade.
Rescinding IRPS 08-2 on Underserved Area Expansions: The letter urges the Board to finalize the rescission of IRPS 08-2 to help promote financial inclusion by reducing the paperwork burdens associated with expanding into underserved areas. The association said the ruling is redundant with the existing Chartering Manual and contains outdated references from 2008 that no longer align with current agency nomenclature.
Rescinding IRPS 10-1 on Community Credit Union Definitions: The CCUA said it supports removing IRPS 10-1 to streamline the community chartering process and consolidate requirements into a single location: the Chartering Manual codified at Appendix B to Part 701. The letter contends that treating these interpretive rulings as “one-off” regulations creates unnecessary burdens by requiring credit unions to check multiple sources to ensure compliance.
Removing Section 701.31 Nondiscrimination Requirements: The CCUA supports the removal of Section 701.31 because it is a duplicative summary of the Fair Housing Act and Equal Credit Opportunity Act, which are already administered by other federal agencies like HUD and the CFPB.
“Rescinding this rule eliminates potential inconsistencies and acknowledges that the NCUA’s updates have not kept pace with modern legal interpretations of these foundational nondiscrimination statutes,” the CCUA said.
