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Its lack of a financial stability mandate under the Dodd-Frank Act has kept NCUA out of a proposal for a new Systemic Issues Committee released by a public policy group headed by former Federal Reserve Chairman Paul Volcker.

This proposal and others are contained in The Volcker Alliance's report, "Reshaping the Financial Regulatory System." The report presents numerous recommendations for reorganizing the federal financial regulatory system, but these do not suggest any changes for NCUA.

The report suggests that a new SIC be established by the Financial Stability Oversight Council and assume authority to designate "systemically important financial institutions." The Fed would write rules addressing any SIFI activities or practices that pose a threat to systemic stability; such rules would be implemented by a new Prudential Supervisory Authority.

Like the NCUA chair, the Treasury secretary would be excluded from the new SIC. The Treasury secretary is left out to maintain its independence. As to NCUA's exclusion, report says, "The NCUA does not have a financial stability mandate or supervisory or regulatory authority over any financial institution requiring enhanced prudential standards necessary for maintaining financial stability."

Another way of reading that, says NAFCU Senior Vice President of Government Affairs and General Counsel Carrie Hunt, is that credit unions are not considered potential threats to the financial system. "This is just another indication that credit unions do not need any additional regulation," said Hunt.

The SIC would include the heads of the Federal Reserve, FDIC, Federal Housing Finance Agency, CFPB, Treasury Office of Financial Research, a combined Securities and Exchange Commission and Commodity Futures Trading Commission, and a state insurance commissioner.

The report is intended to serve as recommendations for legislation.