WASHINGTON--In four proposals issued by the NCUA as part of its Deregulation Project, America’s Credit Unions filed comments offering support, the trade group reported.
Those proposals supported by comments include:
Chartering and Field of Membership (FOM) for Federal Credit Unions (FCUs) -- IRPS 08-2: The proposal eliminates Interpretive Ruling and Policy Statement (IRPS) 08-2, and America’s Credit Unions wrote that it will aid FCUs by pointing them to a single, definitive regulatory text: Appendix B to Part 701. The proposed rescission will make it easier for FCUs to “understand and cite a single, controlling authority, reduce ambiguity, and ensure that outdated rules do not create confusion for credit unions researching FOM regulations.”
Chartering and FOM for FCUs – IRPS 10-1: Offering for support for the proposal to rescind IRPS 10-1, America’s Credit Unions noted the NCUA’s FOM and chartering rules are currently codified in Appendix B to Part 701 and reflect the NCUA’s most current interpretations of the Federal Credit Union Act’s (FCU Act) provisions. Now, all current information pertaining to FOM and chartering rules is now consolidated in the Chartering Manual.
Nondiscrimination Requirements: America’s Credit Unions noted that the NCUA’s proposal to remove a regulation that summarizes Fair Housing Act (FHA) prohibitions on discrimination related to real estate related loans, appraisals, and advertising will “ease regulatory burdens for FCUs by removing a redundant and outdated regulation that risks creating inconsistencies with other federal laws.” The letter highlighted that more comprehensive federal laws already exist in this area, specifically the FHA and Equal Credit Opportunity Act, along with their implementing regulations, such as the CFPB’s Regulation B.
Corporate Credit Unions: Comments from America’s Credit Unions also offered support for the agency’s proposal to remove IRPS 11-02, which addresses chartering corporate credit unions, due to its redundancy. The letter noted its removal would eliminate potential confusion and reduce regulatory burden for FCUs by limiting the number of sources that they must check to ensure compliance with laws and regulations on chartering corporate credit unions.