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NAFCU firmly supports the NCUA's proposal on credit union appeals, as it would provide a "simple and consolidated process for appeals," NAFCU Senior Regulatory Affairs Counsel Michael Emancipator wrote in an official comment letter to the agency Thursday.

The NCUA's proposal, issued in May, would standardize the appeals process by developing a uniform set of procedures for all appeals to the agency. Other substantive regulations would be cross-referenced in a new part created to address appeals. "NAFCU believes that homogenizing the appeals procedure into one, consolidated regulation, … would greatly increase credit union comprehension of the appeals process," Emancipator wrote.

Emancipator also outlined several other changes that NAFCU would encourage the NCUA to consider. Among these is conducting an agency review of current operations to determine what efficiencies can be achieved.

He noted, for example, that the NCUA's current process for reviewing a field-of-membership application fails to provide notifications or status updates on a federal credit union's request until a final decision is reached. "Applicable to the proposal under consideration, an FOM application process that incorporates automated, electronic updates could facilitate better information sharing between the applicant and NCUA, thereby negating the need for an eventual appeal of a final decision," Emancipator wrote.

Emancipator also recommended that the NCUA establish a credit union advisory council and increase utilization of the Office of the Ombudsman.