CUNA’s goal is to ensure a fair distribution of the charges for the supervision of credit unions, consistent with the Federal Credit Union Act, for all credit union regardless of charter type. CUNA submitted these comments to NCUA Friday in response to the agency’s request for comment on the Overhead Transfer Rate (OTR) and Operating Fee schedule methodology.

The proposal would clarify that for the purpose of calculating the operating fee, the budget for capital projects would be included within the total annual budget subject to the OTR.

“CUNA has consistently opposed any overhead transfer of agency expenses to the National Credit Union Share Insurance Fund (NCUSIF) that is not for legitimate, substantiated “insurance-related” costs, consistent with fairness to state and federal credit unions and the Federal Credit Union Act,” the letter reads. “We believe the proposed changes represent an approach that will maintain fair and consistent assessments.”

CUNA also encouraged NCUA to increase the operating fee exemption for credit unions below $10 million in assets.

The letter also contains comments on NCUA’s voluntary Diversity Self-Assessment, designed to help credit unions assess existing diversity and inclusion policies and practices.

“We appreciate the agency’s efforts to encourage participation in the assessment, including through a possible discount to the operating fee for FCUs. We believe such an approach may yield greater results in terms of credit union participation in the assessment,” the letter reads. However, if the NCUA pursues a discount, in keeping with the theme of equality and fairness, it is imperative that a corresponding discount be available for federally insured state-chartered credit unions that participate in the assessment.”

CUNA also noted to NCUA that it believes it is important the assessment remain voluntary for credit unions.