comment letter

Letters support asset reporting threshold, CLF rules

(May 28, 2021) Comment letters on NCUA’s interim final rules on asset thresholds for reporting purposes, and for conforming existing NCUA’s Central Liquidity Facility rules with new statutes, were submitted...

Key comments: Opposition to provisions of RBC simplification proposal

(May 14, 2021) Two significant comment letters were submitted this week by the state system, on simplification of risk-based capital requirements and on adding an “S” for sensitivity to market...

Key comments: Support for adding ‘S’ for ‘sensitivity’ to exam rating system

(May 14, 2021) Moving expeditiously on adding a “market risk sensitivity” component to the credit union examination system – that is, adding an “S” to “CAMEL” – would better align...

States need same ‘beneficial ownership’ info too

(May 7, 2021) State regulators must have access to the same “beneficial ownership” information that federal agencies will have under legislation adopted last year, and made available through a database,...

Letter outlines concern over CUSO reporting requirements

(May 7, 2021) Possible, additional reporting requirements for state credit unions because of a proposed new rule on credit union service organizations (CUSOs) is a key concern outlined by the...

NASCUS supports raising threshold for ‘complex’ CUs to $500 million

(March 26, 2021) The state system supports raising the asset threshold to $500 million for defining a credit union as “complex” under risk-based net worth (RBNW) requirements, citing the benefit...

Letter seeks clear communications on rules for state charters

(March 12, 2021) Clear communication to federally insured state credit unions (FISCUs) of which regulations do and do not apply to them – and also providing a clear chain of...

Capitalization of interest rule needs ‘expeditious’ decision, NASCUS writes

(Feb. 5, 2021) A proposed rule allowing credit unions to capitalize interest should be finalized “expeditiously,” NASCUS said in a comment letter to NCUA this week, noting its support for...

‘Guidance’ offered on supervisory guidance proposal

(Jan. 8, 2021) The state credit union system supports NCUA’s efforts to clarify how it will treat supervisory guidance issued by the agency in the context of examination and supervision,...

States back proposed derivatives rule, with two suggestions

(Jan. 8, 2021) NASCUS supports NCUA’s proposed derivatives rule, but has made two recommendations to the agency that the association said would make the proposal more flexible for the needs...