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NAFCU Vice President of Regulatory Affairs Ann Petros wrote to the NCUA yesterday in response to the agency’s annual regulatory review, sharing various recommendations on 14 of the regulations up for review.  

In the letter, Petros writes that “NAFCU looks forward to an open dialogue with the agency regarding opportunities to modernize, improve, and find appropriate flexibilities in existing regulations so that credit unions may grow and better serve their communities.”     

Petros made new requests to the agency, including an inquiry on the implementation of the Credit Union Governance Modernization Act (CUGMA) and more flexibility on credit union meeting and voting requirements. She also flagged areas to modernize investment and deposit and activity rules, noting that the requirement in 703.11(a) is “overly burdensome and extremely outdated.”   

The letter also reiterated many of NAFCU’s previous comments to the NCUA, such as: 

·       Field of membership (FOM) reform, noting the survivorship issue and the need to expand the “service facility” definition;   

·      Issues related to clarity for the stress testing and capital planning requirements for large credit unions 

·       A request to propose a rule regarding compensation for loan officers and to adopt a floating interest rate ceiling; and   

·       Recent asks on loan participations and to reduce the occupancy requirements from 50% to 25% for credit union premises.   

NAFCU will continue to make these requests and recommendations, including during the association’s upcoming Congressional Caucus, happening September 11 -14.