Comments Due to NAFCU: Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (“Second Chance IRPS”)
NAFCU would like to highlight the following:
- The proposed Second Chance IRPS would amend and expand the current de minimis exception to reduce the scope and number of offenses that would require an application to the NCUA
- The proposed Second Chance IRPS would not require an application for insufficient funds checks of aggregate moderate value, small-dollar simple theft, false identification, simple drug possession, and isolated minor offenses committed by covered persons as young adults.
- The proposed Second Chance IRPS seeks comment on whether the Board should delegate responsibility of reviewing certain applications to streamline the application process.
Comments due to NAFCU: September 13, 2019
Comments due to FHFA: September 27, 2019
NAFCU will send comments on behalf of its members to the NCUA by their deadline (September 27, 2019).