ALEXANDRIA, Va.--The Defense Credit Union Council Monday filed a comment letter with NCUA supporting the recent proposal to simplify and modernize regulations governing records preservation programs.
In its comments, DCUC supported the proposed updates to definitions, the flexibility allowing destruction of outdated records once current versions are preserved, and the NCUA’s decision not to mandate specific retention periods for individual documents. DCUC said it also "strongly supported" removing Appendix A and Appendix B from Part 749, noting these sections are not regulatory requirements.
While supporting regulatory modernization, DCUC agreed the NCUA should retain Part 749 to provide credit unions with additional clarity and guidance under existing statutory recordkeeping requirements.
DCUC also recommended removing proposed language encouraging credit unions to consult legal counsel when establishing retention periods and language related to third-party service provider oversight, stating both additions are unnecessary.
Overall, DCUC said the proposed changes would reduce compliance burdens and improve the regulation’s usefulness for credit unions.