comment letter

Featured Story

Comment Letter Due: Federal Credit Union Bylaws Relating to Expulsion of a Member

NCUA Proposed Rule Summary: Federal Credit Union Bylaws Relating to Expulsion of a Member Read NASCUS Legislative and Regulatory Affairs Department Summary Here September 27, 2022 During the September 22, 2022, NCUA Board...

Comment Letter Due: Proposed Rule on Subordinated Debt

Notice of Proposed Rulemaking and Request for Comment NCUA: Subordinated Debt Read NASCUS Legislative and Regulatory Affairs Department Summary Here October 5, 2022 At the September 22, 2022, NCUA Board...

Comments Due: Policy Statement on Prudent Commercial Real Estate Loan Accommodations and Workouts

MEMBER BENEFIT: Click here to read the NASCUS summary proposed policy. Joint Policy Statement Summary: Prudent Commercial Real Estate Loan Accommodations and Workouts The Office of the Comptroller of the...

Comments Due to NCUA: Cyber Incident Notification Requirements for Federally Insured Credit Unions

MEMBER BENEFIT: Click here to read NASCUS’s summary of the proposed rule. Proposed Rule: Cyber Incident Notification Requirements for Federally Insured Credit Unions Due to the increased frequency and severity...

Comment Letter to Appraisal Subcommittee

March 14, 2022 — The National Association of State Credit Union Supervisors (“NASCUS”) submitted a letter in response to the Appraisal Subcommittee (ASC) of the Federal Financial Institutions Examination Council...

BRIEFLY: 4 job openings in MA; CFPB seeks info on ‘junk fees;’ FDIC insurance director to retire; Agency selects new CLF president

(Jan. 28, 2022) Four new positions are being filled by the MA Division of Banks, the agency said this week. The MA openings include those for consumer protection examiner I...

Comment letter urges focus on risks from consolidation, climate change rules

(Jan. 28, 2022) While acknowledging that industry consolidation and regulation related to climate change are two risks NCUA should consider in the context of its five-year strategic plan, NASCUS wrote to...

Sub debt amendment OK, but other changes needed

(Oct. 29, 2021) Now is the time to consider additional changes to the new subordinated debt rule – rather than adopt just one change to the rule — to ensure...

Coordination among regulators crucial on digital assets, letter argues

(Oct. 29, 2021) Coordination with state and other federal regulators on regulation of decentralized finance (DeFi) and other emerging uses of digital assets is crucial to avoid conflicting rules and...

CCULR OK, but some considerations needed, NASCUS writes

(Oct. 22, 2021) The state system supports the NCUA proposed rule establishing a “complex credit union leverage ratio” (CCULR), as well as a quick implementation of a final regulation, but...

Reg review letter urges reorganizing rules

(Aug. 20, 2021) Reorganizing its rules to lessen confusion over application of anti-money laundering rules, and working with state regulators to implement those rules, are among the recommendations made by...

NASCUS: NCUA approach to NOL must accept tie between OTR, budget

(July 30, 2021) Any discussion about the normal operating level (NOL) of the federal credit union share insurance fund must acknowledge that the actual equity ratio of the fund is...