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In three separate editorials published Friday and over the weekend, NAFCU highlights the regulatory burden facing credit unions, the need for changes in field-of-membership rules and why NCUA's second risk-based capital proposal isn't necessary.

NAFCU President and CEO Dan Berger, discussing credit unions' regulatory burden in a Credit Union Times editorial, noted the association's Top Ten list of regulations that need to be fixed or eliminated. The list promotes regulatory relief such as more-meaningful regulatory exemptions for small institutions, expanded credit union investment authority and improvements in the process for credit unions seeking changes to their fields of membership.

NAFCU Senior Vice President of Government Affairs and General Counsel Carrie Hunt, in an editorial published in Credit Union Journal, says flexible field-of-membership requirements are at the top of NAFCU's list for effecting positive change for credit unions.

"While NAFCU hopes the NCUA Board's unanimous support for exploring ways of strengthening the federal credit union charter will help expedite the review process [of FOM restrictions], we firmly believe that credit unions need action now," Hunt wrote.

In an editorial in Credit Union Today, Berger describes why NCUA's second risk-based capital proposal "is an inappropriate use of credit union resources to address concerns about a few credit union outliers." NAFCU holds that capital reform is best addressed at the legislative level; Berger says instead of this broad new proposed rule, NCUA should address supervisory concerns on a case-by-case basis.

Berger also notes NAFCU's disagreement with NCUA's interpretation of the "Federal Credit Union Act" to support RBC2's two-tier RBC standard.