NCUA should promulgate new rules or expand existing ones only if they are clearly warranted based on a compelling need, CUNA wrote to the agency Thursday. CUNA sent its comments in response to NCUA’s annual review of one-third of its regulations.
The letter also adds that CUNA continues to believe the process to seeking comments on regulations included in NCUA’s regulatory review could be improved’
“For example, some of the rules included for review may already be the subject of proposed changes or recent modifications. In such instances, it is unclear the extent to which further amendments to those regulations will be contemplated by the agency,” the letter reads. ‘’In addition, since the notice of the regulatory review is not required to comply with the Administrative Procedure Act (APA), and is therefore not published in the Federal Register, potential commenters may be unaware of its issuance. To ensure adequate input is received, we ask the NCUA to consider ways to better highlight its request for comments on the regulatory review.”
Regulations included in the review (and CUNA’s comments) include:
Credit union service organizations (CUSOs)
Supervisory Committee audits and verifications
Appraisals
Central Liquidity Facility (CLF)
Requirements for insurance
Appeals procedures