NAFCU Letter on FSOC and Regulatory Coordination

May 20, 2013

The Honorable Tim Johnson
Senate Committee on Banking, Housing
and Urban Affairs
United States Senate
Washington, D.C. 20510

The Honorable Michael Crapo
Ranking Member
Senate Committee on Banking, Housing
and Urban Affairs
United States Senate
Washington, D.C. 20510

Re: The Financial Stability Oversight Council and Regulatory Coordination

Dear Chairman Johnson and Ranking Member Crapo:

On behalf of the National Association of Federal Credit Unions (NAFCU), the only trade association that exclusively represents the interests of our nation’s federal credit unions, I write today as the committee prepares to receive testimony from Treasury Secretary Jack Lew in his capacity as the Chairman of the Financial Stability Oversight Council (FSOC). NAFCU member credit unions appreciate the committee’s oversight with respect to this body of regulators.  We are hopeful that the FSOC will take seriously its duty to facilitate regulatory coordination for our nation’s credit unions and their 95 million member-owners.

As members of the committee are aware, our nation’s credit unions are struggling under an ever-increasing regulatory burden. A survey of NAFCU members late last year found that 94% have seen their regulatory burden increase since passage of the Dodd-Frank Act in July 2010. Credit unions, many of which have very small compliance departments, and in some instances a single compliance officer, must comply with the same rules and regulations as our nation’s largest financial institutions that have the luxury of employing armies of lawyers. Furthermore, these compliance burdens are often compounded as new rules and regulations flow out of multiple regulators, often with little coordination on when they are released.  As member-owned cooperatives, resources spent on regulatory compliance at credit unions are undoubtedly taking away from the services and products credit unions are able to offer to consumers.

As the tide of regulation rises, there has never been a more critical time for the FSOC, led by Secretary Lew, to facilitate regulatory coordination among its member regulators. This duty includes facilitating information sharing and coordination among the member agencies of domestic financial services policy development, rulemaking, examinations, reporting requirements and enforcement actions. As outlined in the attached letter to then Treasury Secretary Timothy Geithner in June of 2012, under the Dodd-Frank Act the FSOC is effectively charged with ameliorating weaknesses within the regulatory structure therein providing a safe and more stable system as a whole. NAFCU appreciates the committee’s focus on the activities of the FSOC and looks forwarding to learning more about the steps that have been taken to avoid duplicative and over burdensome regulation of our nation’s credit unions.

As detailed in NAFCU’s five-point plan for regulatory relief delivered to Congress in February, we believe regulatory relief is critical to the survival of credit unions. Accordingly, NAFCU is committed to pursuing every avenue – through the regulatory agencies and legislatively through Congress – possible to ensure credit unions are provided with real and substantial relief moving forward. Ensuring that the FSOC fulfills its duty to facilitate regulatory coordination would be a positive step in assisting our nation’s credit unions as they navigate this unprecedented, and oftentimes unwarranted, amount of government regulation.

Thank you for the opportunity to comment on this important matter. If you have any questions or would like further information, please do not hesitate to contact me or NAFCU’s Vice President of Legislative Affairs Brad Thaler by telephone at (703) 842-2204 or by e-mail at


Fred R. Becker, Jr.

President and CEO

cc:        Members of the Senate Banking Committee

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