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DCUC provides comments to NCUA on DIMIA thresholds and share insurance requirements

WASHINGTON, DC (July 8, 2026) |

The Defense Credit Union Council (DCUC) has recently submitted two  comment letters to the National Credit Union Administration (NCUA) addressing proposed  regulatory changes affecting credit unions. 

In its first letter filed on Thursday, July 2, DCUC expressed support for the NCUA's proposal to  increase the Depository Institution Management Interlocks Act (DIMIA) asset thresholds to $10  billion, reflecting the significant growth of financial institutions since the thresholds were  established in 1996. DCUC noted that modernizing the thresholds would reduce unnecessary  regulatory burden while preserving safeguards against anticompetitive management interlocks  among the largest institutions. 

DCUC supports establishing a single $10 billion threshold for both institutions involved in an  interlock, creating a more consistent and predictable regulatory framework aligned with other  federal financial regulators. However, DCUC opposed the proposed elimination of the rebuttable  presumption protecting management interlocks involving institutions led by women and minority  groups, noting that the NCUA has not demonstrated that removing the provision would improve  supervision or reduce burden. 

In addition, DCUC provided official comments on the agency's proposal to amend the format of  its regulations governing share insurance requirements. While supportive of the NCUA's  broader deregulatory efforts, DCUC expressed concern that the proposal would not  meaningfully reduce compliance burden and could eliminate valuable cross-references that help  credit unions identify applicable requirements. 

In the letter, DCUC encouraged the NCUA to prioritize reforms that deliver measurable  reductions in operational complexity and compliance costs and recommended supplementing  the rulemaking process with stakeholder roundtables and listening sessions to better identify  unnecessary regulatory burdens. 

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