March 22, 2016

NAFCU: Move to 18-month exam cycle doable now

NAFCU presses its case for moving low-risk credit unions to an 18-month examination cycle, authority for credit unions to purchase mortgage servicing rights and more in its comment letter sent to NCUA Tuesday on a fourth and final round of regulatory review.

NCUA is completing its voluntary review of regulations following a program set by the Economic Growth and Regulatory Paperwork Reduction Act of 1996. In this final round, the agency sought input on existing rules related to rules of procedure and safety and soundness.

Michael Emancipator, NAFCU's senior regulatory counsel, said in Tuesday's comment letter that moving to an 18-month exam cycle for low-risk credit unions is "a prudent path forward to providing regulatory relief to credit unions while simultaneously helping NCUA control examination costs."

NCUA has indicated a willingness to consider returning to a longer exam cycle for well-run credit unions, but it has also said it's not ready to do it yet. Reasons given include ongoing rulemaking and changes being made to call report and AIRES software. Emancipator says no delay is necessary.

"While NAFCU appreciates the fact that the Call Report and AIRES software needs to be modernized, we do not believe that an update needs to be complete before moving to an 18-month examination cycle," he writes. "Rather, NAFCU urges the agency to develop an 18-month examination strategy in concert with updates to requisite software needs."

In other comments, Emancipator urges the agency to to keep focusing its efforts on evaluating new products and services that would benefit credit unions. "NAFCU and our members ask that the agency permit credit unions to purchase mortgage servicing rights, … which are currently listed as a prohibited investment under section 703.16" of the agency's rules and regulations.

Other recommendations in the NAFCU letter include:

  • more guidance for federal credit unions on investments that are permissible by statute;
  • ample information and opportunity for credit unions to weigh in on any proposal on supplemental capital; and, among other things,
  • increased efforts to mitigate the impact of rules on small credit unions.