WASHINGTON (3/24/16)--The National Credit Union Administration (NCUA) can take several steps toward making examinations less burdensome for credit unions, the Credit Union National Association (CUNA) told the agency this week. CUNA submitted a comment letter on the agency’s review of its regulations conducted under the Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA).
The NCUA voluntarily participates in EGRPRA reviews, since the agency does not technically fall within the bill’s definition of “appropriate federal banking agency.”
Six sections of NCUA regulations were open for comment. The list and CUNA’s comments are:
CUNA also added a comment regarding the NCUA’s stated intentions to add an “S” (for sensitivity to market risk) to the CAMEL rating system and revise the “L” to reflect only liquidity issues.
“We urge the NCUA to consider the unique structure of credit unions when considering such a change. CUNA suggests interest rate risk, liquidity, and contingency funding are all interrelated and the current procedures under the existing ‘L’ and existing ‘M’ can adequately identify issues in a credit union,” the letter reads. “While we understand the supervisory guidance for those categories may need to change over time, it does not necessarily warrant the establishment of a new category under the CAMEL rating system.”