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NAFCU Director of Regulatory Affairs Alicia Nealon on Monday urged NCUA use its 2015 Regulatory Review as an opportunity to provide regulatory relief to credit unions. This year's review addressed one-third of NCUA regulations, including those relating to field of membership, credit union bylaws, and loan participations.

Nealon also highlighted NAFCU's revised "top ten" list of regulations to eliminate or amend, which she attached to her letter.

"Acknowledging this increasing regulatory burden, NCUA Chairman Matz announced in March 2015 that the agency was ‘committed to making 2015 the year of regulatory relief,'" Nealon wrote. "NAFCU agrees that the agency needs to focus on ways to provide much-needed relief to credit unions, many of whom are struggling to survive in a post-Dodd-Frank environment characterized by overwhelming compliance burdens."

Nealon also raised concerns about the Financial Accounting Standards Board's plans to finalize a new standard for the financial reporting of credit losses, which she noted would require credit unions to artificially increase balance sheet allowances and reduce available capital. Nealon also reiterated NAFCU's concerns about CFPB's planned payday rulemaking and the growing threat posed by cyber attackers. Nealon urged NCUA to work with FASB, CFPB, and other financial regulators to develop a "common-sense and coordinated" approach to credit union issues.

Among Nealon's suggestions for regulatory updates were:

• streamline the process of applying for FOM expansions or conversions and remove non-statutory requirements imposing geographic- and population-based limitations on community charters;
• modernize the federal credit union bylaws to give credit unions more flexibility, and
• increase clarity in the loan participation regulations in an effort to encourage more credit unions to take advantage of loan participations.

Nealon also shared NAFCU's suggestions relating to executive compensation, designation of low-income status, fixed-assets, capital adequacy, investment and deposit activities, and credit union mergers.