More than six months into the COVID-19 crisis, the credit union industry continues to face new issues, CUNA wrote to NCUA Chairman Rodney Hood Wednesday. The letter is CUNA’s latest engagement with NCUA on pandemic-related issues, CUNA has sent several previous letters and CUNA leaders have met with Hood and other NCUA staff.

CUNA’s letter reiterates several specific concerns it is hearing from credit unions and members, and includes policy recommendations.

These include asking NCUA to:

• Explore ways to reduce the denominator of the net worth ratio, including by excluding zero- and low-risk assets from the net worth ratio calculation;
• Permit credit unions to capitalize interest on consumer mortgage loans in connection with loan modifications made during the pandemic;
• Further delay the effective date of the risk-based capital rule to, at earliest, Jan. 1, 2023;
• Forbear on any assessments;
• Revisit the recently tabled interim final rule on overdraft policy that would allow credit unions to adopt reasonable, flexible policies for members to resolve overdrawn accounts rather than the current 45-day time limit;
• Issue an interim final rule eliminating the requirement that a borrower be a member of a credit union for at least one month before receiving a Payday Alternative Loan I (PAL I); and
• Provide additional guidance for credit unions assisting financially distressed borrowers with outstanding PALs.