NASCUS comments on NCUA's proposed rule to change the definition of "small credit unions
November 27 – In response to NCUA's proposed rule to change the definition of "small credit unions," NASCUS suggested recommendations on behalf of the state credit union system including considering relief for credit unions based on metrics other than just size, such as non-complexity. NASCUS acknowledges in the letter that this rulemaking is specifically related to a Congressional mandate to relieve burden on "small" entities .
"Compliance burden is expected to increase on all financial institutions, and this burden puts the most pressure on small institutions," said NASCUS President and CEO Mary Martha Fortney. "As such, NASCUS supports NCUA's proposal to adjust this threshold and to review it at least every three years."
In supporting the proposed rulemaking, NASCUS' letter notes that state regulators agree that enacting safe and sound regulatory relief for credit unions is appropriate and necessary. Furthermore, NASCUS points out that NCUA could reduce confusion among credit unions by including in any final rule a discussion of those rules utilizing a $10 million asset threshold for compliance that would be unchanged by NCUA proposal to change the definition of small credit union.
"NASCUS remains committed to working with NCUA to leverage the partnership between state and federal regulators to reduce regulatory burden on federally insured state-chartered credit unions in a safe and sound manner," NASCUS stated in the letter.
To view the complete letter, follow this link.