CUNA appreciates NCUA’s budget process transparency but questions the continual increasing budget trend, it wrote to NCUA in response to the agency’s proposed 2022-23 budget. CUNA Senior Economist Mike Schenk presented on the budget Wednesday at NCUA’s public budget briefing.

“We believe there is immense capacity for NCUA to reduce its footprint, right-size the organization and become a more nimble, stronger, more efficient, and more effective regulator,” the letter reads.

The letter notes CUNA—and an “overwhelming majority” of CUNA members—concerns around any expansion in consumer protection examination activity, as it appears to be beyond the scope of NCUA’s primary objective, and that the credit union-member relationship is an incentive discouraging anti-consumer behavior.

“NCUA examiners are keenly focused on any hint of anti-consumerism and they take their jobs very seriously. Credit union members need no significant additional investment of NCUA resources to protect them from the institutions they own,” the letter reads. “Rules, regulations, and examinations should be tailored so they are not overly burdensome on credit unions.

“Consumers lose when one-size-fits-all rules and burdensome examinations force credit unions to pull back safe and affordable options from the market, pushing consumers into the arms of unregulated entities engaged in the very activity that NCUA hopes to curtail,” it adds.

CUNA also noes its opposition to proposed National Credit Union Share Insurance Fund changes supported by NCUA Chairman Todd Harper, including granting the NCUA board broader discretion on the assessment of premiums.

“We believe any changes to the NCUSIF are unwarranted and counterproductive. Credit union members need their credit unions in the market working to improve their financial well-being and advancing the communities that they serve,” the letter reads. “Making the changes Chairman Harper proposes would take money out of credit union members’ accounts to over-insure a Fund that historically has performed its function very well.”

CUNA also reiterated its support for legislation to provide NCUA temporary flexibility to offer forbearance from PCA to otherwise healthy credit unions impacted by federally declared emergencies or disasters.