CUNA generally supports NCUA’s proposed changes to appeals procedures, as it would provide more uniform board appeals procedures across NCUA regulations allowing for informal appeals to the board. CUNA responded Monday to both proposed rules, issued by NCUA at its May board meeting.
The proposed changes to the appeals process would adopt procedures governing appeals to the board that would apply to agency regulations that currently have their own embedded appeals provisions. The procedures apply in cases in which a decision rendered by a regional director or other program office director is subject to appeal to the board.
“CUNA generally supports the proposed appeal procedures rule as it would provide more uniform board appeals procedures across NCUA regulations that allow for informal appeals to the NCUA’s board,” the letter reads. “We agree that the proposed procedures will result in greater efficiency, consistency, and better understanding by credit unions of the way in which matters under the covered regulations may be appealed to the NCUA board.”
CUNA also generally supports the proposed changes to the supervisory review committee (SRC) procedures for appealing material supervisory determinations. The proposed rule would expand the number of issues that can be appealed to the SRC, and would also expand the SRC and update its operating rules.
“Credit unions will benefit from the NCUA adding an intermediate level of appeal and expanding the definition of “material supervisory determination” to allow additional NCUA staff decisions to be appealed to the SRC,” the letter reads.
CUNA supports the expansion, optional intermediate level of review and urged NCUA to report appeals decisions at all levels to the public