CUNA submitted its comments on NCUA’s proposed 2021 budget Friday, following CUNA Chief Economist Mike Schenk’s presentation before NCUA at last week’s briefing.

NCUA’s proposed budget reflects a 0.1% decline from the previous year, and CUNA commends the agency due to proposed activities and expenditures generally aligning with previously announced and vetted strategic. CUNA also believes it also appropriately responds to changing supervisory priorities in light of the COVID-19 Crisis.

“We believe there is immense capacity for NCUA to reduce its footprint, right-size the organization and come out of the resulting transition as a nimble, stronger, more efficient and more effective regulator,” the letter adds.

Highlights include:

• Concerns over any expansion of consumer protection examination activity, as CUNA believes examinations should stay close to NCUA’s mission to ensure the safety and soundness of the credit union system;
• CUNA urges the agency to resist temptations to pursue legislation that transforms the National Credit Union Share Insurance Fund into a “bank-like entity,” as well as commit to reduce the Normal Operating Level to a level closer to its 1.30% historic norm; and
• CUNA calls on NCUA to use the pandemic as a reference point for additional meaningful field of membership reform.

CUNA also commends the agency for continuing to provide comprehensive budget information and a rationalization of the budget and agency expenditures in advance, as well as holding an open briefing.

The board is scheduled to vote on the budget at its Dec. 18 meeting.