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Aug. 26, 2014 – NAFCU Regulatory Affairs staff wrote NCUA on the agency's proposed rules on asset securitization and appraisals, with suggestions based on the association's push for regulatory relief for credit unions.

NAFCU Regulatory Affairs Counsel Angela Meyster wrote with the association's comments on the agency's proposed rules on asset securitization, which would clarify that credit unions can securitize loans which they have originated, provided the transactions meet certain requirements. Meyster urged NCUA to expand the eligibility of loans beyond those originated by the securitizing credit unions, and to replace the fixed threshold at which credit unions may hold residual and retained interests with a sliding scale linked to risk.

"In considering changes to the proposed rule, NAFCU believes NCUA should focus primarily on protecting credit unions and their members by making available to them a robust and viable securitization regime," Meyster wrote. "Accordingly, NCUA should not develop a securitization regime that requires overburdensome and unnecessary provisions related to investors at the expense of ensuring that credit unions may serve the best interests of their members through the use of securitizations."

Regulatory Affairs Counsel PJ Hoffman wrote NCUA on the proposed rule on appraisals, which is a part of NAFCU's "Dirty Dozen" list of rules to be eliminated or amended for regulatory relief. Hoffman in particular focused on the inconsistency between requirements regarding making copies of appraisals and written valuations under CFPB requirements and NCUA requirements, and urged the agency to continue to implement changes advocated by the "Dirty Dozen" list.