CUNA submits comments on NCUA’s annual regulatory review

WASHINGTON, DC (May 31, 2019) — The National Credit Union Administration (NCUA) is soliciting input on its annual review of one-third of the agency’s regulations in an effort to determine those that need to be updated, clarified, simplified or eliminated. Credit Union National Association (CUNA) submit a letter for the record stating that NCUA should only promulgate new or expand existing rules only if they are warranted based on a compelling need. The cumulative regulatory burden on credit unions is near an all-time high and CUNA supports the continued review of NCUA regulations to determine whether they should be updated, clarified, simplified, or eliminated.

“Since the notice of the regulatory review is not required to comply with the Administrative Procedure Act (APA), and is therefore not published in the Federal Register, potential commenters may be unaware of its issuance. To ensure adequate input is received, we ask the NCUA to consider ways to better highlight its request for comments on the regulatory review,” CUNA Senior Director of Advocacy and Counsel Luke Martone writes. “Since the regulatory review process is outside the APA, comments are not made available for public inspection.

“In addition, the NCUA does not publicly respond to commenters’ suggestions. While not required to do so, it would be very useful if the NCUA were to choose to not only post public comments on its website but also publicly respond to input received. Doing so would permit CUNA, and credit unions alike, to identify patterns and/or trends within the regulations included in the review,” Martone adds. “This would allow for more effective and efficient advocacy, and ideally result in an improved operating environment for credit unions.”

While CUNA commented on most regulations up for review, highlights on specific areas include:

  • Federal credit union chartering and field of membership: CUNA applauds NCUA for its efforts to improve several field of membership processes, but also believes the agency can accomplish even more to improve the field of membership regulation;
  • Federal credit union bylaws: CUNA highlighted issues raised in its comment letter on NCUA’s bylaws proposal, including supporting aspects of changes to bylaw amendments, concerns with reductions of individuals available to achieve a quorum and encouraging NCUA to permit electronic voting in elections if the credit union determines it’s the most appropriate way;
  • Low-income credit unions: CUNA urges NCUA to review the low-income designation to provide a path for additional credit unions to qualify, provide greater transparency with respect to qualification thresholds and enhance certainty about what happens should a credit union drop below a threshold; and
  • Corporate credit unions: CUNA notes it is looking forward to working with NCUA on a thorough review of the corporate credit union regulation to ensure the regulation does not impose unnecessary constraints on corporate credit unions’ ability to respond to innovations in the financial services marketplace.

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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