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NAFCU Director of Regulatory Affairs Alicia Nealon raised concerns about NCUA's proposed reduction to the timeline for formulating and submitting capital plans required under the agency's capital planning and stress testing rule.

Nealon also reiterated NAFCU's strong opposition to the cost and regulatory burden associated with unnecessary NCUA-conducted stress testing.

NCUA's 2014 final rule requires annual stress testing for federally insured credit unions with $10 billion or more in assets. Nealon notes that the proposed amendments "also fail to justify the burden they will place on covered credit unions," and she specifically raised concerns about the proposed reduction of the capital plan submission timeframe by 30 days.

NCUA has said the proposed change is meant to make its stress testing schedule conform with that of the Federal Reserve, FDIC and the Office of the Comptroller of the Currency.

"While NAFCU supports the proposal's effort to bring NCUA's scenario release date into parity with the banking agencies' schedule, we disagree with the proposed adjustments to the due date for capital plan submissions because it would unjustifiably reduce the time from five months to four months," Nealon wrote.

NAFCU supports the proposed change of the capital plan "as-of-date" from September to December in order to mirror banking agencies' schedules, but believes the submission date should then be May 31 in order for credit unions to have five months to complete their capital plans. Nealon also noted NAFCU's recommendation that NCUA switch all capital planning and stress testing schedule dates to mirror that of the banking agencies'.