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NCUA issued a supervisory letter this month on capital planning and stress testing to guide field staff for the Office of National Examinations and Supervision in reviewing related activity at credit unions with $10 billion or more in assets.

The letter focuses on evaluating and approving a federally insured credit union's capital plan under NCUA's final rule Part 702, specifically sections 702.503 and 702.504 on capital policy and planning, respectively.

NAFCU supports NCUA doing all it can to ensure the health of the National Credit Union Share Insurance Fund, but it continues to have concerns about the regulatory burden and cost associated with the agency's rule on capital planning and stress testing.

"We have been arguing for less, not more, regulatory burden in our conversations with NCUA, other regulators and Congress," NAFCU Director of Regulatory Affairs Mike Coleman said of the final stress test rule. "This final rule significantly ramps up current burdens and increases costs for all insured credit unions. While NAFCU recognizes that importance of a strong, healthy National Credit Union Share Insurance Fund, we believe this final rule does little to enhance the fund's security and instead adds unnecessary and inappropriate regulatory burden on credit unions."

NAFCU shared numerous concerns about the proposed rule prior to its adoption, key among them the cost of requiring agency-led stress testing when affected credit unions are already performing their own stress tests regularly.

The agency also put out a white paper this month titled, "Principles of Capital Policy and Capital Planning," which also focuses on the final rule and how credit unions can create capital plans compliant with regulations.