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CUs: Comment on NCUA's annual reg review
NAFCU is currently seeking comment from member credit unions on the NCUA's 2020 Regulatory Review, published earlier this year by the agency's Office of General Counsel. The review, conducted annually, evaluates one-third of current regulations for regulatory burdens, administrative hurdles, and clarity.
Through a new Regulatory Alert, NAFCU highlights that the regulatory review process:
- welcomes comments on whether rules are clearly articulated and easily understood, as well as recommendations for substantive changes; and
- covers sixteen parts of the NCUA's rules and regulations, including Credit Union Service Organizations, leasing, incidental powers, appraisals, commercial lending, accuracy of advertising and notice of insured status, share insurance, and more.
NAFCU notes that the regulatory review process provides an opportunity for credit unions to provide the NCUA with feedback regarding regulations that are "unclear, out of date, redundant, difficult to work with, or which create unintended consequences and unnecessary regulatory burdens for credit unions."
The association would like members' feedback on:
- whether a federal credit union’s non-controlling or de minimis investment in a CUSO be exempt from the investment limits in Part 712;
- if the appraisal rule’s current definition of a “complex” transaction be revised or should the NCUA provide more guidance on the definition;
- whether any of the temporary changes to the Central Liquidity Facility regulation in Part 725 should be made permanent, rather than sunsetting on December 31;
- if the NCUA should provide exceptions or guidance regarding the NCUA advertising requirements for digital and social media advertisements; and
- should NCUA alter its existing guidance on capitalizing interest in loan workouts and troubled debt restructured loans.
NAFCU also breaks down the 16 regulations that are under review this year and provides questions to consider. Credit unions are encouraged to submit comments to NAFCU by July 17. Comments are due to the NCUA Aug. 3.