CUNA submitted comments Friday on NCUA’s annual review of one-third of its regulations. In addition to its comments on the specific recommendations, CUNA called on NCUA to improve the process for soliciting input.
“We believe the process for seeking comments on regulations included in the 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,” the letter reads. “In such instances, it is unclear the extent to which further amendments to those regulations will be contemplated by the agency.
“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,” it adds. “To ensure adequate input is received, we ask the NCUA to consider ways to better highlight its request for comments on the regulatory review.
CUNA also urged NCUA to promulgate new or expand existing rules “only if such rules are clearly warranted based on a compelling need: and to “strongly consider the current regulatory burden on credit unions as it proceeds with this and future regulatory reviews.”
CUNA offered substantive input on the following regulations: