Comments on several proposals, including NCUA’s 2020-21 operating budget, are due in December. CUNA presented at the budget briefing conducted by NCUA earlier this month.

The proposed 2020 operating budget is $316.2 million a 3.9% increase over last year. Comments are due to NCUA Dec. 2. The board is expected to vote on the budget at its Dec. 12 meeting.

Other comment deadlines this month include:

• Dec. 9: NCUA field of membership proposal. NCUA proposes to re-adopt a provision to allow an applicant to designate a Combined Statistical Area (CSA), or an individual, contiguous portion thereof, as a well-defined local community (WDLC), provided that the chosen area has a population of 2.5 million or less. It also proposed to clarify existing requirements and add an explicit provision to its rules to address concerns about potential discrimination in the FOM selection for CSAs and Core Based Statistical Areas;
• Dec. 16: Interagency policy statement on allowances for credit losses. The proposed statement describes the measurement of expected credit losses under the current expected credit losses (CECL) methodology; supervisory expectations for designing, documenting, and validating expected credit loss estimation processes, including the internal controls over these processes; maintaining appropriate allowances for credit losses (ACLs); the responsibilities of boards of directors and management; and examiner reviews of ACLs;
• Dec. 16: Interagency guidance on credit risk review systems. Federal regulators are inviting comment on proposed guidance discussing sound management of credit risk, a system of independent, ongoing credit review, and appropriate communication regarding the performance of the institution's loan portfolio to its management and board of directors;
• Dec. 19: Federal Housing Finance Administration (FHFA) request for comment on Uniform Mortgage-Backed Securities (UMBS) pooling practices. FHFA seeks public input on Fannie Mae's and Freddie Mac's pooling practices as they relate to the formation of “To-Be-Announced” (TBA)-eligible UMBS. FHFA is also seeking public input about other policies and practices that might affect UMBS fungibility, including the Enterprises' oversight of seller/servicer refinance policies and their monitoring of seller/servicer-specific UMBS prepayment speeds.