What CUNA Wants To See In NCUA’s Strategic Plan

WASHINGTON—Going forward, NCUA should strive to achieve measurable and reportable forms of regulatory relief for credit unions, CUNA said in a letter to the agency this week.

CUNA submitted a comment letter on the agency’s draft strategic plan for 2017 to 2021.

CUNA stressed the need for continued regulatory relief for credit unions, noting that recent NCUA efforts have helped, but credit unions continue to feel pressure from other regulators, such as the Consumer Financial Protection Bureau.

“NCUA has the most control over how the agency constructs and conducts the supervision process for the vast majority of credit unions, which is where the strategic plan should focus on reducing supervisory burdens,” CUNA wrote. “NCUA should develop a stated goal of reducing credit unions' time dedicated to the supervision process, develop a way to measure success and then strive to meet this goal and hold staff accountable to this goal.”

CUNA urged the NCUA to pursue a larger goal of a percentage reduction in time and resources that credit unions must commit to the NCUA’s supervision process. The letter goes on to suggest that CUNA’s comprehensive regulatory burden study could be used as a baseline to measure any improvement that NCUA strives to make.

CUNA also encouraged the NCUA to:

  • Make a public commitment to move forward with implementation of the extended exam cycle;
     
  • Introduce every new or revamped NCUA requirement or process directed to credit unions with the stated goal of being more efficient and less burdensome to credit unions;
     
  • Develop a strategic initiative with metrics as part of the review process detailing the agency’s success in reviewing and addressing regulatory issues;
     
  • Develop and state in the strategic plan its goals for the implementation and operation of a revamped call report and AIRES software. Stating that software is due to be in service by a certain time is one of many operational goals that should be included in the strategic plan;
     
  • Develop goals and metrics for improving the dual exam process for state-chartered credit unions, including setting efficiency goals for dual examination and working with state regulators to implement efficiency measures; and
     
  • Add an initiative to develop greater offsite monitoring capability by NCUA staff. “This could allow staff to spot supervisory issues earlier and require less NCUA staff onsite for exams and other supervisory related issues,” CUNA wrote. 
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