WASHINGTON–America’s Credit Unions has sent two letters to Capitol Hill, the first to the House Financial Services Committee outlining its priorities ahead of NCUA Chairman Kyle Haputman’s testimony today, and the second to FinCEN outlining areas where it said improvements can be made to help eliminate “false positives.”
In the letter sent for the hearing’s record, America’s Credit Unions Senior Vice President of Advocacy Greg Mesack expressed ongoing support for the agency’s proposed 2025 budget reduction, for its efforts to modernize and reduction, and for its move to eliminate reputational risk in examinations and supervision.
Recommendations Made
In the letter, the trade group also says NCUA should:
- Maintain the current 18% temporary interest rate ceiling for federal credit unions beyond its expiration in March 2026
- Align with recent federal financial regulator reforms by modernizing examination scope and frequency and clarifying the standards for “unsafe or unsound practices” and formal exam findings
- Provide additional clarity on what custodians of stablecoins or stablecoin reserves may do with those funds beyond general safekeeping, and their status collateral for lending purposes while implementing the GENIUS Act
- Pursue targeted capital relief or credit unions that aligns with the Nov. 25 proposal from federal bank regulators that would implement changes to the community bank leverage ratio framework; and
- Consider working through the Federal Financial Institution Examination Council to overhaul the CAMELS rating system, with a particular focus on the management (M) component.
The full letter can be found here.
Letter on Incomplete FinCEN Data
Separately, America’s Credit Union argued in a second letter that credit unions are receiving incomplete data in information requests from the Financial Crimes Enforcement Network (FinCEN), which is creating “large numbers of false positives” and forcing employees to conduct time-consuming manual reviews that provide “little value to law enforcement.” America’s Credit Unions outlined recommendations to reduce this unnecessary compliance burden while improving the quality and usefulness of information credit unions provide to FinCEN and law enforcement in letter sent Monday.
The letter, from Regulatory Advocacy Senior Counsel Luke Martone, was sent in response to FinCEN’s request for comment (RFC) on information collection requirements under section 314(a) of the USA PATRIOT Act.
According to America’s Credit Unions, Martone noted the biggest challenge for credit unions when complying is the “frequent absence of core identifiers” such as date of birth, address, or taxpayer identification numbers.
Recommendations & Points Raised
In the letter, Martone:
- Recommended FinCEN require law enforcement to provide more details when gathering information to help financial institutions distinguish between similar names.
- Urged FinCEN to include clearer guidance, advance notice for unusually large requests, alerts when corrected files are issued, and expanded access to standardized training.
- Raised concerns about the lack of feedback credit unions receive after submitting 314(a) responses, Suspicious Activity Reports, or Currency Transaction Reports, “making it difficult to assess whether their reporting supports law-enforcement efforts.”
- Highlighted the value of the voluntary section 314(b) information-sharing framework as related to fraud and illicit activity. “We recognize that the scope of 314(b) is defined by the text of the USA PATRIOT Act and that expanding its coverage would require statutory action. If policymakers consider targeted updates to allow more effective fraud-related information sharing, we strongly request Treasury’s support for such efforts,” he wrote.
