Recent NCUA actions have been positive for credit unions, but there are areas the agency can improve, CUNA wrote to the House Financial Services Committee Tuesday. The committee will hear semi-annual testimony Wednesday from NCUA Chairman Rodney Hood, and CUNA’s letter was sent for the hearing’s record.

CUNA’s letter also calls on NCUA to continue coordination with other federal regulators, including but not limited to the Consumer Financial Protection Bureau and the Federal Communications Commission.

Recent actions that have been positive for credit unions include NCUA’s:

• Recognition of the importance of data and cyber security, and its commitment to make it an area of focus. CUNA supports Hood’s recent efforts to bolster the agency’s involvement in cybersecurity;
• Commitment to addressing unnecessary regulatory burden, including the agency’s decision to respect the spirit and intent of President Donald Trump’s executive order to reduce regulatory burden and the work of the agency’s Regulatory Reform Task Force;
• Continuing to provide comprehensive budget information and rationalization of budget and agency expenditures in the contact of a well-communicated strategic plan;
• Recent efforts to extend the examination cycle for certain credit unions;
• Efforts to streamline examinations and make operations more efficient; and
• Work to modernize the call report.

Areas in which NCUA can improve include:

• The risk-based capital rulemaking, which CUNA continues to believe is a solution in search of a problem;
• Employing a more pro-active and collaborative strategy with industry stakeholders to better ensure credit unions are prepared for the current expected credit loss (CECL) standard;
• Creating and providing a concrete, public plan to achieve regulatory relief;
• Extending the credit union asset threshold for the 18-month examination cycle to $3 billion (from the current $1 billion);
• Phasing down the National Credit Union Share Insurance Fund Normal Operating Level to 1.30% by 2021. CUNA also encourages NCUA to issue additional share insurance fund distributions whenever possible, with the expectation that the initial increase in the NOL was temporary.

The letter also noted that NCUA board member Todd Harper’s proposed expansion of NCUA’s Office of Consumer Protection is not warranted.