NAFCU’s Berger: NCUA’s TCCUSF closure proposal not in best interest of CUs

WASHINGTON, DC (August 29, 2017) — National Association of Federally-Insured Credit Unions (NAFCU) President and CEO Dan Berger today wrote the National Credit Union Administration (NCUA) reiterating the association’s opposition to the NCUA’s proposed raising of the National Credit Union Share Insurance Fund’s (NCUSIF) normal operating level and the merging of the stabilization fund into the NCUSIF.

“Although there could conceivably be short-term benefits to merging the Stabilization Fund with the SIF, NAFCU strongly believes such a move at this time would not be in the best interest of credit unions,” wrote Berger. “Therefore, NAFCU and our members: (1) stand in opposition to NCUA’s proposal to merge the funds at this time; (2) strongly oppose any increase to the NOL; and (3) advocate that the agency is not required to charge a premium in 2017.”

The NCUA proposal, issued in July, would raise the NCUSIF’s normal operating level from 1.3 percent to 1.39 percent. NAFCU’s Board of Directors along with two member-filled committees – the Regulatory and NCUSIF Committees – unanimously oppose this proposal.

Berger noted that if the NCUA moves forward with the current proposal, credit unions would only receive about 40 percent of what is “rightfully their money.” He called it a “cash grab” and said it amounts to a “60 percent premium charged to the industry.”

“In rushing such a complex proposal, NCUA is attempting to distract credit unions with the promise of dividends as the agency hoards nearly $800 million for itself by increasing the NOL to the highest level in the history of the SIF,” Berger wrote. “That money should rightfully be returned to credit unions that made sacrifices as a result of the Stabilization Fund assessments.”

In the letter, Berger explained that the NCUA has the legal authority to distribute refunds to the industry now without merging the two funds. He also highlights how the proposal violates the statute and amounts to an “impermissible” premium assessment.

Berger also stated that the NCUSIF’s normal operating level is set appropriately and that, regardless of whether the funds are merged, the NCUA does not need to charge a premium. NAFCU’s models show that the equity ratio will not fall below 1.20 percent until after 2019, Berger explained.


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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