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October 29, 2015

NAFCU: No justification for NCUA's added CUSO data collection

NAFCU on Wednesday told NCUA the association disagrees with the agency's plan to collect additional information directly from credit union service organizations, including their customer lists, for a registry.

"NCUA already has the information it needs to effectively oversee credit union relationships with CUSOs, as well as discern what services credit unions garner from CUSOs," NAFCU Senior Regulatory Affairs Counsel Michael Emancipator told NCUA in a letter Wednesday. NCUA hopes to determine the full range of CUSO activity in the marketplace through this registry, but, Emancipator said, there "does not appear to be a direct nexus between a CUSO Registry and a CUSO's customer list."

The NCUA Board issued a final rule on CUSOs in 2013. The rule requires CUSOs to report certain financial and operational information to NCUA and applicable state authorities on a yearly basis. The rule also calls for the creation of a CUSO Registry.

Emancipator said NCUA will likely need to increase its budget to cover the added CUSO data collection. "NAFCU does not support spending credit union resources to expand NCUA's oversight of CUSO activities," he wrote.

He added, "NAFCU firmly believes the most appropriate and least burdensome way for NCUA to address the perceived issues surrounding CUSOs is to continue examining third-party vendor relationships through the agency's examination process."

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