NCUA urged to review TISA, CUSO burdens
Oct. 7, 2013 – NAFCU on Friday urged NCUA to review the disclosure requirements of the Truth in Savings Act and a pending credit union service organization final rule for opportunities to reduce the associated burden and expense for credit unions.
NAFCU Regulatory Affairs Counsel Angela Meyster, writing the agency on the TISA disclosure requirements, said, “NAFCU believes that credit unions should be allowed to make the disclosures required under Part 707 in electronic form wherever feasible. Many credit union members prefer to receive information electronically, and an electronic interface allows credit unions to communicate disclosures, updates, and other important messages with their members much more quickly and efficiently than via paper.”
However, Meyster wrote that while electronic disclosure should be the default, members should also be given the option to opt-in to paper disclosures at their request. She noted that since credit unions operate as not-for-profit cooperatives run by and for their members, the resources they expend on burdensome compliance requirements are resources they won’t have to serve their members.
Likewise, NAFCU Regulatory Affairs Counsel PJ Hoffman urged NCUA to reevaluate its proposed rule to extend the agency’s regulatory authority over CUSOs.
NCUA’s July 2011 proposal would extend the agency’s regulatory authority over CUSOs by requiring them to submit financial reports directly to the agency. NAFCU holds this is beyond NCUA’s authority designated by Congress.
“Given that the NCUA already gets the information it needs about CUSOs, it need not attempt to regulate and oversee CUSOs in the manner that it has proposed,” Hoffman wrote. “CUSOs have proven to be strong partners for credit unions to meet their members’ needs, and an important source of cost savings.”
Hoffman also took issue with NCUA’s estimate of the annual burden cost per credit union to comply with its proposal – $17,737. He said that figure does not account for the resources credit unions must expend for collection, data management and maintenance of CUSO financial information.
CUSO OMB Request comment letter (10-4-13)
TISA OMB Request comment letter (10-4-13)