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NAFCU urged NCUA to keep its focus on transparency and operational and regulatory improvements – including moving healthy credit unions back to an 18-month exam cycle – in a comment letter Monday on the agency's strategic direction for the next five years.

In January, the NCUA Board released its 2017-2021 strategic plan, summarizing three goals: safety and soundness, financial literacy and a diverse and skilled workforce at the agency.

NAFCU Senior Regulatory Affairs Counsel Michael Emancipator, writing Monday, noted NAFCU's ongoing concerns regarding NCUA's budget increases. Also, under the agency's safety and soundness goal, he commented on the consolidation within the credit union industry, balancing risk mitigation with innovation, vendor management, cybersecurity and examination cycles.

He reiterated NAFCU's strong support to move healthy credit unions to an 18-month exam cycle as a way to provide regulatory relief for credit unions and reduce NCUA's costs.

On vendor authority, Emancipator wrote, "NAFCU disagrees with the assertion that third-party vendor examination and enforcement authority will provide any significant improvement to credit union safety and soundness." He said such authority for NCUA "would only impose significant costs on credit unions."

Emancipator also touted credit unions' financial literacy education programs that help consumers make informed decisions.

Regarding NCUA's goal of having a skilled and diverse workforce, Emancipator encouraged the agency to "continue evaluating the cost-benefits of using third-party contractors for projects that require highly specialized personnel, but are not needed for on-going concerns core to the agency's mission."