WASHINGTON—America’s Credit Unions and the Defense Credit Union Council (DCUC) have submitted separate comment letters to the National Credit Union Administration as part of the agency’s Deregulation Project, offering their feedback and views on proposals related to chartering and FOM, mergers and insurance-related disclosures, and conversions of credit unions to mutual savings banks.
Below is a look at what the trade groups told NCUA:
Chartering and Field of Membership (IRPS 06-1)
Both groups expressed support for the NCUA’s proposal to rescind Interpretive Ruling and Policy Statement 06-1, which governs aspects of chartering and field-of-membership compliance.
America’s Credit Unions said the IRPS is largely redundant with existing guidance in the Chartering and Field of Membership Manual and that its removal would streamline compliance by reducing the number of sources federal credit unions must consult. The organization added that consolidating guidance would improve clarity and efficiency without weakening oversight, as the underlying requirements would remain unchanged.
DCUC similarly supported the proposal, stating that the provisions in IRPS 06-1 are already incorporated into the Chartering Manual and that eliminating the separate policy statement would reduce compliance burden and simplify adherence to field-of-membership requirements. The group added the change would be particularly beneficial for smaller institutions and would streamline oversight while maintaining safety and soundness.
Mergers and Insurance-Related Disclosures (Part 708b)
The two organizations diverged more sharply on proposed changes to Part 708b, which governs mergers and the termination or conversion of federal share insurance.
America’s Credit Unions supported the NCUA’s proposal to eliminate the requirement that the agency publicly post member comments submitted in connection with merger proposals, arguing the change would better protect member privacy and reduce administrative burden. The group also backed removing prescriptive formatting requirements for mandatory disclosure statements tied to insurance conversions or terminations, saying credit unions should have flexibility in communicating key information, while emphasizing that disclosures must remain clear and accessible.
Opposed to Elimination
DCUC, however, opposed eliminating the requirement allowing members to submit comments and requiring the NCUA to make those comments publicly available. The organization said those provisions serve a critical transparency function by providing a formal mechanism for member feedback, offering visibility into member sentiment and reinforcing confidence in merger decisions. DCUC argued that even a low volume of comments provides useful insight and said the absence of comments can itself be informative.
At the same time, DCUC supported removing detailed formatting requirements for disclosures related to the loss or termination of federal share insurance, calling them unnecessarily burdensome and agreeing that a general standard is sufficient.
Conversions to Mutual Savings Banks (Part 708a)
Both groups supported elements of the NCUA’s proposal to streamline rules governing conversions of federally insured credit unions to mutual savings banks, while DCUC raised concerns about certain provisions.
America’s Credit Unions endorsed removing prescriptive procedural and disclosure requirements, describing the current framework as overly complex and costly. The organization said simplifying the process would reduce unnecessary burden while preserving core member protections, including voting rights and access to material information about proposed conversions.
DCUC expressed mixed support for the proposal. The group backed eliminating requirements such as publishing conversion notices in newspapers, calling them outdated, and supported removing detailed prescriptive provisions governing member communications and filings, as well as non-binding voting guidelines from regulatory text.
However, DCUC opposed eliminating the regulatory definition of “clear and conspicuous,” arguing that the standard provides important objective criteria—such as formatting and font size—that ensure consistent compliance and consumer understanding. Removing that definition, DCUC said, could introduce uncertainty and inconsistent supervision.
Broader Deregulation Effort
Across their respective letters, both organizations expressed support for the NCUA’s broader Deregulation Project, which is being conducted in phases and is expected to continue through 2026.
America’s Credit Unions emphasized that targeted regulatory relief can improve operational efficiency while maintaining safety and soundness, provided transparency is preserved.
DCUC similarly supported modernization efforts but repeatedly urged the agency to strike a balance between reducing burden and maintaining clear standards and protections, particularly in areas affecting member rights and major structural changes such as mergers and conversions.
2 Responses
Smart Deregulation Must Preserve Transparency, Accountability, and Member Trust
As the National Credit Union Administration (NCUA) advances its Deregulation Project, the National Council of Firefighter Credit Unions (NCOFCU) welcomes the opportunity to weigh in on reforms that will shape the future of our movement. Representing institutions that serve first responders and their families, we understand both the operational pressures credit unions face and the critical importance of maintaining member trust.
In reviewing the recent comment letters submitted by America’s Credit Unions and the Defense Credit Union Council (DCUC), we find substantial common ground with both organizations. At the same time, NCOFCU aligns more closely with the DCUC’s approach—one that appropriately balances regulatory relief with the preservation of transparency, consistency, and member protections.
On chartering and field-of-membership requirements, we agree with both trade groups that rescinding Interpretive Ruling and Policy Statement 06-1 is a sensible step. As noted, the provisions are already embedded within the NCUA’s Chartering Manual, and eliminating duplicative guidance will streamline compliance without weakening oversight. For firefighter credit unions—many of which are small and resource-constrained—clarity and efficiency in regulatory expectations are essential.
However, where the proposals touch directly on member rights and institutional accountability, we believe a more cautious approach is warranted.
Regarding mergers and insurance-related disclosures, NCOFCU shares DCUC’s concern about eliminating the requirement for public member comments. While privacy considerations are important, transparency is foundational to the cooperative model. The ability for members to provide input—and for that input to be visible—reinforces confidence in merger decisions and ensures that leadership remains accountable to those they serve. Even limited participation offers valuable insight, and silence itself can be meaningful. Removing this mechanism risks diminishing the member voice at precisely the moments when it matters most.
At the same time, we support efforts—endorsed by both groups—to modernize and simplify disclosure formatting requirements. Credit unions should have flexibility in how they communicate with members, provided the information remains clear, accessible, and meaningful.
On conversions to mutual savings banks, NCOFCU again finds merit in both perspectives but ultimately aligns more closely with DCUC’s measured stance. We support eliminating outdated and overly prescriptive requirements, such as newspaper publication mandates, and reducing unnecessary procedural complexity. However, we share DCUC’s concern about removing the regulatory definition of “clear and conspicuous.” Objective standards for disclosures are not mere technicalities—they are essential safeguards that ensure members fully understand significant structural changes. Without them, we risk inconsistent practices and diminished consumer protection.
At its core, the NCUA’s Deregulation Project presents an opportunity to modernize rules in a way that strengthens—not weakens—the credit union system. NCOFCU supports thoughtful regulatory relief that reduces unnecessary burden and enables credit unions to better serve their members. But deregulation must not come at the expense of transparency, accountability, or the cooperative principles that define our industry.
First responder credit unions operate on trust, trust built in moments of crisis and carried through everyday financial services. As such, we urge the NCUA to adopt a balanced approach: streamline where appropriate but preserve the standards and safeguards that protect members and sustain confidence in our institutions.
In this effort, the perspective advanced by DCUC offers a prudent path forward—one that recognizes that effective regulation is not simply about reducing rules, but about ensuring the right rules remain in place.
Grant Sheehan CCUE | CCUP | CEO, NCOFCU
Spicy: https://thecudaily.com/group-representing-small-cus-objects-to-ncua-proposal-to-nix-member-to-member-communications-in-merger-proposals/