WASHINGTON—As CUToday.info reported here, in a comment letter sent to NCUA CUNA put an emphasis on an overhaul of the agency’s rules for CU bylaws as part of comment on the one-third of NCUA rules that are up for review each year.
But in addition to that comment, CUNA also pressed NCUA to review:
- Field of Membership. CUNA reiterated its call as expressed in previous comment letters for the NCUA to provide more flexibility on various field of membership issues as the federal charter is falling behind many state charters.
- Designation of Low-Income Status – CUNA urged NCUA to do more to allow credit unions to obtain the designation and requested NCUA to revise the procedure for losing the designation to allow more certainty for credit unions.
- Prompt Corrective Action. CUNA reiterated its concern on the Risk-Based Capital 2 proposal and continued the concern over the statutory authority to set a risk-based standard for determining whether a credit union is well-capitalized, as opposed to adequately capitalized. Specifically, it called for the elimination of the capital adequacy requirement. CUNA continues to believe that the proposal is a solution to solve a problem that does not exist in the credit union system.
Other areas addressed included: OREO properties; executive compensation in connection with loan growth; loan participations; check-cashing for non-members; mergers and conversions; and other technical areas.