KENNEWICK, Wash. — Although he has yet to take office, Endangered Small Credit Union Defense (ESCUD) has sent a letter to incoming National Credit Union Administration Chairman John Crews outlining what it called a series of regulatory changes that it said could provide immediate relief to small credit unions without requiring congressional action.
In the letter to Crews, who has had his confirmation hearing but who has not yet been approved by the Senate, ESCUD urges the agency to focus on “practical, risk-based regulatory relief” for credit unions with less than $500 million in assets.
ESCUD, a 501(c)(4) advocacy organization representing 34 endorsing credit unions with more than 200,000 members and more than $1.5 billion in combined assets, praised the NCUA for several deregulatory actions taken under former Chairman Kyle Hauptman in which the group said it provided input.

Actions Highlighted
Among the actions highlighted by ESCUD were:
- Eliminating the requirement for supervisory committee signatures on Agreed-Upon Procedures audit engagements.
- Directing examiners to accept supervisory committee reviews of biennial account verifications rather than repeating the work.
- Providing flexibility under the Board Modernization Act that allows qualifying small credit unions to hold fewer board meetings.
- Updating vital records guidance to permit the disposal of older documents that no longer serve a business purpose.
“These steps demonstrate a genuine commitment to right-sizing regulation for institutions that pose minimal risk to the NCUSIF,” ESCUD said in the letter.
The organization also cited results from its January 2026 survey of small credit union CEOs, which it said found regulatory compliance burden ranked as the second-largest threat to financial health after competition from larger institutions. ESCUD said concerns over examination practices—including what respondents described as “examiner over-compliance pressure” and “examination exhaustion”—ranked among the most significant challenges facing small institutions.
According to the survey, nearly 75% of respondents expressed little confidence their credit union would remain independent and thriving over the next decade.
Three Regulatory Priorities Recommended
ESCUD urged Crews to prioritize three regulatory initiatives that it said fall within the NCUA’s existing supervisory authority:
- Adopt more risk-based examination staffing, scope and frequency for healthy CAMELS 1- and 2-rated credit unions, including extending exam cycles to 24 months where appropriate.
- Limit Documents of Resolution to material safety-and-soundness concerns while reducing examiner focus on minor compliance issues.
- Expand the agency’s reliance on supervisory committee reviews and qualified third-party audits rather than duplicating testing during examinations.
The organization also encouraged the NCUA to pursue additional regulatory relief consistent with President Donald Trump’s March 13 executive order on expanding access to mortgage credit. Those recommendations included reduced enforcement of NMLS/SAFE Act requirements for low-volume lenders, continued support for raising CECL thresholds and working with the Consumer Financial Protection Bureau on targeted Home Mortgage Disclosure Act relief.
‘Visible Proof of the Difference’
“Small, hyper-local credit unions are the visible proof of the credit union difference,” ESCUD President Doug Wadsworth, who also serves as president of $75 million Tri-CU Federal Credit Union in Kennewick, wrote in the letter. “Protecting their ability to survive and serve underserved members and communities is not only the right thing to do for those members, but it is important for the long-term health and justification of the entire credit union tax exemption.”
ESCUD said it also offered to provide Crews and his staff with survey data, compliance-cost examples and credit union CEO testimonials, and said it is prepared to meet with the incoming chairman to discuss the proposals further.





One Response
Small CU leaders should work together to strengthen management and governance practices instead of advocating for non-compliance with safety and soundness and consumer protection regulations. Until we can stop the fraud and failures within small credit unions, this ongoing advocacy lacks credibility, weakens the movement, and puts our tax exemption at risk.