WASHINGTON--The NCUA’s fifth round of Deregulation Project proposals contains three regulatory relief proposals. America’s Credit Unions filed comments Monday on all three in this phase.
The NCUA proposals include:
Rescinding its Interpretive Ruling and Policy Statement limiting sources that federal credit unions must check to ensure compliance with applicable chartering and field of membership requirements.
- America’s Credit Unions notes that this elimination ensures federal credit unions are better able to meet the compliance standards without superfluous documents, and “the proposed rescission will help federal credit unions simplify their compliance procedures and refer to one authority, increasing efficiency and reducing confusion for credit unions regarding FOM rules.” (Read the letter)
Removing the requirement that NCUA make member comments on a proposed merger accessible and eliminating prescriptive formatting requirements for mandatory disclosure statements related to insurance conversion or termination.
- America’s Credit Unions supports the ability for credit unions to communicate about a potential merger but believes the proposal “appropriately removes outdated and underutilized requirements while preserving core member protections,” and encourages the agency to ensure clear and consistent expectations as these changes are implemented. (Read the letter)
Eliminating certain prescriptive requirements governing the conversion of insured credit unions into banks, aimed at reducing both cost and complexity.
- While America’s Credit Unions does not advocate for policies that would encourage or create incentives for credit unions to convert to bank charters, it recognizes that credit unions “must retain the ability to evaluate all strategic options available to them under law, and we support reasonable efforts to ensure that the regulatory framework governing those options is clear, current, and workable.” (Read the letter)