Interagency proposed rule regarding supervisory guidance

by David Park, NAFCU Compliance Blog

On October 28, the National Credit Union Administration (NCUA) Board approved a proposed interagency rule codifying an interagency statement from September 2018 regarding the role of supervisory guidance. The NCUA joined the Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Federal Reserve), Federal Deposit Insurance Corporation (FDIC) and Consumer Financial Protection Bureau (CFPB) in publishing the proposed rule in the Federal Register on November 5.

2018 Interagency Statement

NAFCU blogged about the interagency statement when it was released. The statement, which was brief, noted that “supervisory guidance does not have the force and effect of law, and the agencies do not take enforcement actions based on supervisory guidance.” The statement provided clarity on the following issues:

  • When numerical thresholds are included in supervisory guidance to describe the agencies’ supervisory expectations, those thresholds are only examples and do not constitute requirements.

 

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