Senators call for EGRPRA action;
NASCUS urges rule consolidation

Feb. 16, 2016 -- Incorporating in one place all of NCUA’s share insurance rules – as NASCUS has urged --would be one way that NCUA could respond to the call of nine senators who last week urged NCUA and other federal financial institution regulators to take action under the Economic Growth and Regulatory Paperwork Reductions Act (EGRPRA) to ease credit unions’ and community banks’ regulatory burden.

In a letter on Friday, Senate Banking Committee members Mike Crapo (R-Idaho), Dean Heller (R-Nev.), Jerry Moran (R-Kan.), Tom Cotton (R-Ark.), Michael Rounds (R-S.D.), Pat Toomey (R-Pa.), Ben Sasse, (R-Neb.), David Vitter, (R-La.), and Mark Kirk (R-Ill.) called on the leaders of NCUA, Federal Reserve, FDIC and the Office of the Comptroller of the Currency to update them on the status of the EGRPRA-mandated interagency review of regulations to eliminate outdated, unnecessary or unduly burdensome rules.

In its most recent comment letter on EGRPRA (for round three, comments for which were due last September), NASCUS pointed out that several of the rules covered by that notice for comment applied to federally insured state-chartered credit unions (FISCUs) by way of incorporation by reference in Part 741, Requirements for Insurance.

“NASCUS continues to urge NCUA to ease the regulatory burden on FISCUs by changing the format of its rules to incorporate in one place all if its share insurance rules,” NASCUS wrote in its Sept. 22 letter. “The current structure of NCUA's Rules and Regulations is unnecessarily cumbersome and confusing for FISCUs and examiners alike. NCUA could erase any confusion, and ease regulatory burden, by systematically reorganizing its Rules and Regulations to provide federal and state examiners, and FISCUs, a consolidated chapter of applicable insurance regulations.”

NASCUS is currently developing comments for a March 22 deadline for EGRPRA round four, which covers 15 subjects in the two categories of “rules of procedure” and “safety and soundness.”

The regulatory review by NCUA is voluntary, as it is not statutorily required to do so. The Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (FDIC) are subject to EGRPRA. 

The agency has conducted three previous regulatory reviews under EGRPRA, which will be included in the formal EGRPRA report to Congress. NASCUS has commented on all three of the previous regulatory reviews, consistently calling for the agency to consolidate – in one place – all of the regulations that apply to FISCUs.


Letter from GOP Senate Banking Committee members

NASCUS summary, EGRPRA Round 4

NASCUS comment letter, EGRPRA Round 3