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NAFCU President and CEO Dan Berger, writing NCUA, yesterday criticized the ever-increasing NCUA budget and said efforts to increase exam flexibility should result in more robust cost savings.

Berger reiterated points submitted for NCUA's Oct. 27 budget briefing, noting that a "runaway budget" is a threat to the credit union industry's safety and soundness, which the agency must do more to mitigate.

"The 2018 budget request for authorized [full-time equivalents] will reflect a decline of 61 positions from a peak of 1,269 in 2015," Berger wrote. "The budget narrative explains that this reduction is due, in part, to the fact that examiners will spend less time at credit unions as a result of increased remote monitoring and pre-exam consultation. Clearly this is a move in the right direction, but these time-saving efforts do not appear to directly correlate or pass-through to budget reductions."

Berger also argued that the size of the agency should decrease as the credit union industry consolidates, and he noted that the agency's growth does not correlate to an increase in the number of federally insured credit unions with complex products. He reiterated NAFCU's call for the NCUA to maintain the National Credit Union Share Insurance Fund's current equity ratio into 2017 and to provide assurances as soon as possible that credit unions will not be charged unnecessary premiums.

Berger urged an extended exam cycle for all well-run, low-risk credit unions and for the creation of a clearer and more objective exam appeals process. He also urged the NCUA to return to a one-year budget process in order to give the bureau more flexibility and in order to increase transparency.

Finally, he reiterated NAFCU's call for a plan to give credit unions a refund from the Temporary Corporate Credit Union Stabilization Fund as soon as possible.