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:

• Part 748: Security Program, Report of Suspected Crimes, Suspicious Transactions, Catastrophic Acts and Bank Secrecy Act Compliance
  • CUNA urges NCUA to minimize compliance burdens related to Bank Secrecy Act/Anti-money Laundering (BSA/AML) regulations under Part 748 and to work with the Treasury, Financial Crimes Enforcement Network, and Congress to support additional meaningful changes to minimize the costs and burdens associated with BSA/AML requirements.
• Part 749: Records Preservation Program and Appendices
  • CUNA asks NCUA to revisit the permanent records detailed in Appendix A to the regulation, which provides guidance concerning how long credit unions should retain certain records.
• Part 760: Loans in Areas Having Special Flood Hazards
  • CUNA encourages the NCUA to consider placing the Interagency Questions and Answers regarding flood insurance in Appendix to Part 760. CUNA believes this would make it easier to locate, less reliant on access to NCUA’s website, and provide certainty that the guidance is the most recent version.