CUNA supports the high-level goals of NCUA’s strategic plan and provided suggestions on achieving  them in comments submitted Monday to the agency. NCUA’s draft strategic plan covers goals and objectives for the next five years.

Specifically, it describes the agency’s proposed strategic goals and objectives for 2022-26, summarizes an analysis of the internal and external environment impacting the NCUA, and evaluates the agency’s programs and risks.

CUNA ‘s comment letter:

• Reiterates its opposition to any changes to the Federal Credit Union Act related to the National Credit Union Share Insurance Fund. NCUA Chairman Todd Harper has called on legislative changes CUNA believes “truly represent a solution in search of a problem.”
• Calls on NCUA to make progress toward its stated goal of providing effective and efficient supervision by reducing the frequency by which it examines smaller credit unions and extending the credit union asset threshold for the 18-month examination cycle to $3 billion (up from the current $1 billion).
• Highlights significant concerns around any expansion in consumer protection examination activity, as there has been no supplementary evidence to suggest credit unions’ consumer compliance management is a systemic risk area.
• Urges NCUA to establish a new Regulatory Reform Task Force to review the agency’s regulations and recommend changes to eliminate outdated, unnecessary, or unduly burdensome requirements
• Encourages NCUA to continue efforts to promote diversity and inclusive and equitable financial services at credit unions.