NAFCU offers recommendations to NCUA on regulatory reform

WASHINGTON, DC (November 21, 2017) — National Association of Federally-Insured Credit Unions (NAFCU) Senior Regulatory Affairs Counsel Michael Emancipator today in a letter to the National Credit Union Administration (NCUA) offered ways in which the agency can reprioritize its regulatory reform efforts.

In the letter, Emancipator commended the NCUA Board’s “commitment to creating a regulatory environment that is safe and sound, yet still enables credit unions to become an even better service provider for the American consumer,” and he offered additional ways to decrease the regulatory burden credit unions face.

One of these would be to stop using an institution’s asset size to determine its risk to the market. Emancipator reiterated NAFCU’s long-held view that “size does not equal risk,” and that view is supported by a recent Office of Financial Research report titled, “Size Alone is not Sufficient to Identify Systemically Important Banks.”

“While NAFCU appreciates that NCUA’s various asset threshold requirements are intended to provide regulatory relief, we stress that the agency should not hinge its determinations on the asset size of the credit union … NAFCU respectfully asks the agency to more closely consider criteria by which a credit union should achieve relief, rather than prohibit relief merely due to asset size,” Emancipator wrote.

Emancipator, with input from NAFCU’s Regulatory Affairs Committee, also recommended the board reprioritize relief efforts based on a taxonomic system, with Tier 1, Class A regulations at the highest priority followed by Tier 1, Class B rules and so forth.

“Under this more nuanced system, credit unions will have greater assurance that the regulatory reforms that mean most to them will be purposed first,” Emancipator noted.


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 or @NAFCU on Twitter.


Molly Safreed, (NAFCU)

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