CUNA seeks changes to NCUA executive compensation regulations

WASHINGTON, DC (June 25, 2019) — The Credit Union National Association (CUNA) today sent a comment letter on the National Credit Union Administration’s (NCUA) advance notice of proposed rulemaking regarding compensation in connection with loans to members and lines of credit to members. NCUA is examining how it can modernize the regulation, including by providing greater flexibility in the area of compensation to credit union executives in connection with loans to members. 

CUNA supports the overall intent of the regulation but believes additional changes are needed to remain competitive with credit unions’ banking counterparts. The letter outlines requested changes to the regulation which would allow additional compensation to senior executives is appropriate, so long as there is an appropriate balance that incorporates sufficient risk management. 

The letter addresses two primary issues: 

  • The need for clarification on the term “overall financial performance.” The regulation permits a bonus to a credit union employee in connection with a loan if the bonus is based on the credit union’s “overall financial performance.” Credit unions have expressed confusion on what factors can be considered when assessing the credit union’s “overall financial performance.” 

  • The current differences between credit union and bank compensation. Based on CUNA research, bank CEO compensation packages consist of a significantly larger percentage of performance-based compensation: approximately 24% of bank CEO compensation is variable (bonus, stocks, and options) versus only 8% at credit unions. Further, the vast majority of small credit unions do not offer any type of bonus. 

NCUA’s current regulations establish a blanket prohibition on any commission, fee, or other compensation to any credit union official or employee, or an immediate family member of either, in connection with any loan made by their credit union, with several exceptions.

About CUNA

Credit Union National Association (CUNA) is the only national association that advocates on behalf of all of America’s credit unions, which are owned by 135 million consumer members. CUNA, along with its network of affiliated state credit union leagues, delivers unwavering advocacy, continuous professional growth and operational confidence to protect the best interests of all credit unions. For more information about CUNA, visit To find your nearest credit union, visit


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