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NAFCU President and CEO Dan Berger, in comment letters Friday, urged NCUA to be fully transparent about the methodologies behind its operating fees and the overhead transfer rate and that the agency board take back oversight of both mechanisms.​

The OTR and operating fees provide the funding for NCUA's budget. NCUA issued a request for comments this January on their methodologies.

Writing on the operating fee methodology, Berger emphasized the importance of instituting a third-party review of the operating fee forecasting models.

"While NAFCU appreciates the agency's efforts to be transparent and objective as it forecasts and indexes the Operating Fee asset thresholds, we urge the agency to conduct a thorough third-party review of its forecast models, similar to the review of the agency's Overhead Transfer Rate methodology," Berger wrote Friday. "NAFCU believes that this review is necessary in order to achieve third-party validation of a fair and objective methodology. This will have the added benefit of increasing the accuracy of agency forecasts, and thus, reducing the need for subsequent fee adjustments."

Berger also urged NCUA to return to board oversight of the operating fee schedule and the OTR. Authority to administer both was delegated to agency staff last fall. Berger also suggested that stating the rationale behind each budget allocation increase would help mitigate concerns that the OTR is being used to offset budget increases.

"NAFCU encourages the agency to commit to ongoing and consistent transparency when calculating the OTR," Berger said in a statement. "NAFCU also continues to urge the agency to find ways to reduce its operating expenses. Any reduction in the operating budget will ultimately reduce OTR's impact on the Share Insurance Fund and benefit the entire industry."

The OTR is used to transfer funds from the National Credit Union Share Insurance Fund to the agency's operating fund to cover "insurance-related" activities. For 2016, the OTR increased from 71.8 percent to 73.1 percent, which NCUA said was due to an increase in the percentage of insured shares held by federally insured, state-chartered credit unions.

The agency's total 2016 budget is set at $290.9 million – up 4.1 percent from the year before.