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NAFCU's Carrie Hunt encouraged NCUA to be aware of regulatory creep and to challenge any unnecessary infringement of its authority by other financial regulators in a CUToday.info editorial published this week.

Hunt, NAFCU's executive vice president of government affairs and general counsel, said several rulemakings by CFPB, Department of Defense and the Financial Accounting Standards Board "either directly or indirectly overstep NCUA's purview as the prudential regulator of credit unions." Many, she added, seem to have been developed without credit unions' unique structure in mind.

As an example, Hunt pointed to CFPB's recent payday lending proposal that would alter provisions in NCUA's payday alternative loan (PAL) program. "While the CFPB incorporated some regulatory language to take the PALs program into account, many parts of the rule are problematic for credit unions," she wrote.

Hunt also noted that NCUA exists as an independent agency because of credit unions' unique structure. "NAFCU would fully support NCUA being an even stronger regulator that works with the credit union community when the industry is under fire – even when it comes from other regulatory bodies," she wrote. "With an average of one credit union disappearing every single day, largely due to regulatory burden, the stakes are too high."