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NAFCU offers recommendations to NCUA on annual regulatory review

WASHINGTON, DC (August 11, 2017) — National Association of Federally-Insured Credit Unions (NAFCU) Senior Regulatory Affairs Counsel Michael Emancipator today wrote the National Credit Union Administration recommending several improvements to the rules currently under review by the NCUA, including those for Bank Secrecy Act compliance, loans in areas with special flood hazards and requests for information via the Freedom of Information Act.

Below please find a summary highlighting recommendations for the agency:

BSA compliance: NAFCU is urging the NCUA to coordinate with the Financial Crimes Enforcement Network to ensure “sensible regulation and exams are tailored to actual risks.” Emancipator added that examiners should focus on the intent and usefulness of suspicious activity reports (SARs) rather than zero-tolerance, technical compliance.

“We recommend that NCUA amend Part 748 to reflect the spirit of the law while still ensuring safeguards are in place to inhibit bad actors from exploiting the financial system,” he wrote. He also requested that NCUA support improvements to FinCEN regulations, such as increased thresholds for filing currency transaction and SARs.

Record retention and catastrophic preparedness guidelines: The NCUA should align these requirements with statutes of limitations. “Maintaining records indefinitely is an administrative burden that exceeds the reasonable intentions of record retention rules,” Emancipator noted.

Flood insurance regulation: NAFCU recommends that the agency provide more flexibility with respect to the delivery and timing of required notices. The NCUA should support legislative efforts that would achieve long-term authorization of the National Flood Insurance Program.

Emancipator also reviewed NCUA’s Board rulemaking process and FOIA requests.

Among other comments, the NAFCU letter urges that the NCUA codify interpretive rulings and policy statements and standardize publication of legal opinion letters. It also reiterates NAFCU’s recommendations regarding model bylaws and the payday alternative loan (PAL) program. Emancipator wrote that NCUA’s “efforts to coordinate with other financial banking agencies to avoid regulations that would surely hamstring credit unions’ efforts to lend are appreciated.”


About NAFCU

The National Association of Federally-Insured Credit Unions is the only national trade association focusing exclusively on federal issues affecting the nation’s federally-insured credit unions. NAFCU membership is direct and provides credit unions with the best in federal advocacy, education and compliance assistance. For more information on NAFCU, go to www.nafcu.org or @NAFCU on Twitter.

Contacts

Molly Safreed, msafreed@nafcu.org (NAFCU)

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