NAFCU letter regarding the NCUA’s 2014-2017 Strategic Plan

January 17, 2014

The Honorable Debbie Matz, Chairman
The Honorable Michael Fryzel, Board Member
The Honorable Rick T. Metsger, Board Member
National Credit Union Administration
1775 Duke Street
Alexandria, VA 22314
RE:  NCUA’s 2014-2017 Strategic Plan

Dear Chairman Matz and Board Members Fryzel and Metsger:

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 regarding the National Credit Union Administration (NCUA) Strategic Plan for 2014-2017 (Strategic Plan).

First and foremost, NAFCU appreciates the opportunity to comment on the NCUA’s Strategic Plan. We believe that dialogue involving the agency and the industry is crucial to ensuring that the credit union industry remains healthy and credit unions continue to be unparalleled in providing quality financial services and products. Approximately 97 million Americans now rely on their credit unions to meet their financial services needs and demands, and now more than ever, the NCUA must carefully assess how its actions will enhance credit unions ability to serve their members rather than unnecessarily inhibit them.

The Strategic Plan addresses many key issues on the horizon. The NCUA correctly identifies a number of risks that credit unions are likely to face, including interest rate risk and cybersecurity. NAFCU recognizes these challenges and we are ready and willing to work with the NCUA to find the best solutions for credit unions and the industry.

As the NCUA implements the Strategic Plan, NAFCU strongly urges the agency against taking a one-size-fits-all approach to any particular problem or issue. For example, the Strategic Plan correctly identifies that rising interest rates will greatly reduce an important current source of income for credit unions, namely, income from refinancings. NAFCU believes that credit unions must be provided adequate flexibility to address this challenge, as a plan or solution that one credit union may find appropriate may not be suitable for another credit union. In addition, credit unions must be granted the necessary authority to address this challenge. This includes granting credit unions additional investment authority and expanding their incidental powers.

NAFCU also believes that the NCUA should do more to work with stakeholders to secure key legislative changes for credit unions. We strongly believe that legislative changes are needed to laws relative to credit union capital. Restrictions on member business lending need to be lifted. Furthermore, cyber- and data-security issues, which include credit unions bearing ever-increasing costs related to merchants’ failures to conduct business in a safe manner, need legislative solutions. The NCUA, we believe, should prioritize achieving landmark legislative changes that are needed and NAFCU stands ready to work with the agency in this regard.

The NCUA’s Strategic Plan should also focus on reducing regulatory burden on credit unions. NAFCU believes that it is essential that the agency conduct a thorough review of its regulations to identify rules that are unnecessary, outdated or overly burdensome on credit unions. For this purpose, NAFCU has prepared a “dirty dozen” list of regulations to eliminate or amend, a copy of which is attached to this letter.

NAFCU looks forward to working with the agency in 2014 and beyond. Should you have any questions or would like to discuss these issues further, please contact Michael Coleman, NAFCU’s Director of Regulatory Affairs, by telephone at (703) 842-2244 or by email at or me by telephone at (703) 842-2215 or by email at


B. Dan Berger
President and CEO

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