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Today is the deadline for NAFCU members to submit comments in response to two Regulatory Alerts: on NCUA's proposed rule on asset securitization and on the agency's proposal to revise appraisal regulations.

The proposed rule would clarify that a natural-person federal credit union is allowed to securitize loans that it has originated, provided that the transaction meets certain requirements. It also sets out seven safety and soundness requirements for eligibility. NCUA has concurrently requested comments on amendments to an existing safe harbor triggered by the agency liquidating a credit union, which would prevent the agency from cancelling any investor's contractual rights under secure asset sales.

NAFCU is requesting comments on the proposal and amendments – particularly regarding whether NCUA should limit securitization to only loans a federal credit union has originated, whether its safety and soundness conditions are sufficient, and whether the safe harbor requirements are too burdensome.

The other Regulatory Alert deadline today concerns NCUA's proposal to revise two regulations relating to appraisals, specifically: eliminating the duplicative requirement for federal credit unions to make copies of appraisals available to members applying for loans secured by the first lien on a dwelling, and expanding the current exemption for certain transactions involving the extension of credit.

NAFCU staff will use input from association members to put together its responses to NCUA on these matters.

Other Regulatory Alert deadlines this month include:

• comments on CFPB's proposed policy statement on expanding its Consumer Complaint Database to include narrative data, due Aug. 11;
• comments on CFPB's request for information on mobile financial services, due Aug. 13;
• comments on the Federal Reserve Board's review under the Economic Growth and Regulatory Paperwork Reduction Act, due Aug. 15; and
• comments on NCUA's review under the EGRPRA, also due Aug. 15.