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June 28, 2012 – NAFCU President and CEO Fred Becker on Wednesday urged Treasury Secretary Tim Geithner to establish within the Financial Stability Oversight Council "robust interagency coordination" on the issuance of rules affecting financial institutions.

Becker noted the numerous agencies involved now in regulating the financial services industry and said the FSOC has a duty to facilitate coordination among those entities.

"This duty includes facilitating information sharing and coordinating among the member agencies of domestic financial services policy development, rulemaking, examinations, reporting requirements and enforcement actions," the NAFCU president wrote. "Through this role, the FSOC is effectively charged with ameliorating weaknesses within the regulatory structure, promoting a safer and a more stable system."

The FSOC, created by the Dodd-Frank Act, includes Geithner and the heads of NCUA, FDIC, the Federal Reserve Board, the Office of the Comptroller of the Currency, the Consumer Financial Protection Bureau and federal securities and commodities regulators.

Becker discussed the array of rules issued from multiple agencies and their impact on credit unions.He noted that the burden from regulation comes not just from one rule, but from the whole array of regulation issued simultaneously from multiple regulators.

"As we have approached each agency regarding the ever-increasing regulatory burden, they quickly respond that the rules being issued by other agencies are outside of their purview," Becker said. "NAFCU believes the FSOC is well-positioned to rectify this lack of coordination."

Becker also urged that the FSOC set policy to require member agencies to conduct and publish a thorough cost/benefit analysis before they issue new rules. They should repeat those analyses one year following implementation and every two years after that, he said.

In addition, the NAFCU president recommended that FSOC member agencies conduct biannual analyses of each regulation on their books and be required to justify their continued existence.

Becker's letter was also copied to the Senate Banking Committee, House Financial Services Committee, the heads of each FSOC member federal regulator and other agencies that regulate credit unions.