NASCUS Encourages NCUA to Consolidate Insurance Rules in Rule Review Comments
August 8, 2011 -NASCUS responded to the National Credit Union Administration (NCUA) 2011 Rule Review in an August 5, 2011 comment letter.
The NCUA maintains a rolling review schedule that identifies one-third of NCUA’s existing regulations for review each year and provides notice to the public for comment. In our comment letter, NASCUS encouraged the NCUA to consolidate insurance rules in one section of NCUA’s Rules and Regulations. NASCUS wrote that consolidating share insurance rules would reduce regulatory burden on state-chartered federally insured credit unions, increase clarity among examiners on application of rules and more clearly distinguish NCUA’s insurance and chartering rulemaking functions.
As currently organized, Part 741 consists of two sections: 741.0-741.11 comprised of standalone insurance rules and Subpart B comprised of other NCUA rules that are incorporated by reference. NASCUS has consistently recommended the NCUA reorganize and consolidate their regulations to reduce regulatory burden. It has long been NASCUS’ experience that identifying which rules incorporated by reference apply to state-chartered federally insured credit unions has caused confusion among credit unions and state and federal examiners.
NASCUS also commented on Part 790 of NCUA’s Rules and Regulations recommending that the NCUA Office of Consumer Protection (OCP) be added to the department descriptions.
To view our comment letter, click here.