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NAFCU President and CEO Dan Berger sent Treasury Secretary Steve Mnuchin a "framework" for how the current administration could create meaningful regulatory relief for credit unions.

Berger highlighted the positive impact regulatory relief would have on the country's credit unions and their more than 106 million members.

Berger in particular noted the "substantively flawed provisions" within the NCUA's risk-based capital rule, including "improper risk-weighting of mortgage servicing rights" and loans and investments to credit union service organizations, among other things.

Berger also discussed the barriers credit unions face when lending to their members and shared concerns about the CFPB's ability-to-repay, qualified mortgage and Home Mortgage Disclosure Act rules.

In the letter, Berger also highlighted credit unions' issues with:

• regulatory overlap and duplication;
• regulatory call reports;
• supervisory examination processes;
• Bank Secrecy Act and anti-money laundering regulations;
• costs of compliance;
• regulatory treatment for the current expected credit loss accounting standard; and
• cost-benefit analysis of regulations.

Berger also thanked Mnuchin for the Treasury Department's recent credit union roundtable held earlier this month, and he urged the department to keep regulatory relief in mind as the administration moves forward.

NAFCU sent a similar framework for regulatory relief to the department's Office of Consumer Policy earlier this month.