The cumulative regulatory burden on credit unions is at an all-time high, CUNA told NCUA in a letter sent Friday. The letter was sent in response to the agency’s annual review of one-third of its regulations to determine whether any can be updated, clarified, simplified, or eliminated.
“As NCUA is aware, the cumulative regulatory burden on credit unions is at an all-time high. Therefore, we urge NCUA to promulgate new or expand existing rules only if such rules are clearly warranted based on a compelling need,” the letter reads. “Similarly, the agency should strongly consider the current regulatory burden on credit unions as it proceeds with this and future regulatory reviews.”
In the letter CUNA supports legislative and regulatory changes to address redundancies and unnecessary burdens within the Bank Secrecy Act/anti-money laundering framework.
CUNA also made suggestions involving flood insurance, expounding on issues raised in a comment letter sent in January.
CUNA advocates for a “safe harbor,” rather than the proposed “compliance aid provision” that provides that a policy meets the definition of private flood insurance if certain criteria are met. “We believe a safe harbor that effectively eliminates or reduces the lending institution’s liability in verifying whether a private insurance policy meets the statutory requirements is more appropriate than a tool that simply assists the lender in complying with the regulation,” the letter reads.
CUNA also added that NCUA’s process for seeking comments on regulations included in the regulatory review could be improved, including posting comments publicly.