An amended merger rule should not increase the burden for the merging or acquiring credit unions, CUNA told NCUA in a comment letter filed Monday in response to the agency’s proposal on mergers. NCUA’s proposed rule would alter the procedures a federal credit union must follow to voluntarily merge with another credit union.

“CUNA agrees that members of a merging credit union should be given enough information to make an informed decision. The amount and type of information required to be disclosed can aid credit unions members in making the proper decision; however, over disclosure or too much information can lead to members being less informed,” the letter reads. “Moreover, NCUA already has tools in place to ensure that mergers are not unduly influenced by credit unions seeking to merge.”

Specifically, CUNA does not support:

• Additional disclosures, which CUNA believes do little to help credit union members decide whether to approve a merger and could slow or stop the process;
   
• Merger notice periods that do not line up with current other NCUA regulations; and
   
• The 15-day, advance member-to-member communication requirement, which CUNA feels is overly burdensome.

In its letter, CUNA adds that credit unions have “significantly benefitted” NCUA recent efforts to reduce regulatory burden.

“Absent a compelling reason or the mandate to satisfy the requirements of a new law, an update to a regulation should not add additional burdensome requirements for credit unions,” the letter reads. “CUNA members have concerns that this proposed rule does so.”

CUNA will continue to work with the NCUA to communicate credit union concerns with the proposed merger rule, to eliminate or reduce any regulatory burden that could result from an updated rule.