WASHINGTON–The Defense Credit Union Council and America’s Credit Unions have both voiced support for a proposal by the National Credit Union Administration to modernize and simplify regulations governing records preservation programs for credit unions.
The proposal is part of the NCUA’s broader Deregulation Project, which the agency said is aimed at reducing compliance burdens on federally insured credit unions while updating outdated regulatory requirements.
DCUC’s comment letter addresses a proposal related to Part 749 of NCUA regulations, which governs records preservation programs for federally insured credit unions. In its comments, DCUC said it supports proposed updates to regulatory definitions, as well as provisions allowing credit unions to destroy outdated records once updated versions have been preserved. The organization said the added flexibility would help improve operational efficiency while reducing unnecessary record storage burdens.
Other Points Made
DCUC also:
- Backed the agency’s decision not to mandate specific retention periods for individual documents.
- Strongly supported the proposed removal of Appendix A and Appendix B from Part 749, noting the appendices are not regulatory requirements.
- Recommended NCUA retain Part 749 itself to continue providing credit unions with clarity and guidance regarding existing statutory recordkeeping requirements.
- Recommended removing proposed language encouraging credit unions to consult legal counsel when establishing retention periods, as well as language related to oversight of third-party service providers. The organization said both additions were unnecessary and could create additional compliance expectations for credit unions.
America’s Credit Unions Supports Plan
Similarly America’s Credit Unions also voiced support for the NCUA proposal.
In its letter to the agency, the trade group said:
- It supports modernization of Part 749 by clarifying its focus on vital records preservation, removing nonbinding guidance from the regulatory text, and preserving credit union flexibility to use current records management and recovery practices.
- It believes the proposal would update and simplify Part 749, keeping the rule focused on vital records needed to restore member services after a catastrophic event, rather than using it as a broader record retention rule.
- It believes removing Appendices A and B clears up confusion and unnecessary burden as they were intended as guidance but have often been treated as mandatory.
- Appendices should be updated and maintained separately as nonbinding guidance, FAQs, or training materials.
- Older versions of vital records may be destroyed unless another law or regulation requires retention. Identifying a record as “vital” does not mean it must be kept permanently.
- That credit unions support modern records practices, including electronic logs, automated backups, third-party providers, and documented procedures, rather than requiring manual record-by-record processes.
- That any change to record keeping should emphasize flexibility for credit unions of different sizes and operations, especially small credit unions with limited staff and storage resources.
