Here’s What Cooperative CU Association Told NCUA About 4 of its Deregulation Proposals

MARLBOROUGH, Mass.–The Cooperative Credit Union Assoiation has filed four comment letters on proposals that are part of NCUA’s Deregulation Project.

The CCUA’s comments included:

  • Maximum Borrowing Authority: The CCUA said it supports the deletion of Section 741.2, which would eliminate redundant borrowing limits for federal credit unions and allow state-chartered institutions (FISCUs) to be governed primarily by state law.
  • Public Unit and Nonmember Shares: The association said it supports removing the specific written planning requirement for credit unions exceeding the 70% threshold, as existing aggregate limits and supervisory processes provide sufficient oversight.
  • Requirements for Insurance: The CCUA said it supports the removal of Section 741.10, noting that its disclosure requirements for nonmember depositors are redundant with existing insurance agreements.
  • Termination of Excess Insurance: The CCUA said it supports providing credit unions with greater discretion regarding the timing of member notifications when terminating excess share insurance, allowing for better alignment with state-level requirements. 

‘Critical Part of Mission’

“These efforts are a critical part of our mission to ensure a flexible and efficient regulatory environment that allows you to focus on serving your members,” the association said. “We will continue to monitor these proceedings and keep you updated as the NCUA moves toward finalizing these rules.”

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