CUNA filed a comment letter Thursday in response to the NCUA’s proposed rule to increase the asset threshold for supervision by NCUA’s Office of National Examinations and Supervision (ONES) for credit unions from $10 billion in assets to $15 billion.

Under the proposed rule, credit unions between $10 billion and $15 billion (that are not currently supervised by ONES) would be supervised by their appropriate NCUA Regional Office. The proposed rule would not alter any regulatory requirements for covered credit unions.

“We are largely supportive of this proposal,” the letter reads. “However, we urge the NCUA to ensure there is sufficient expertise at the Regional Office level to properly supervise this new asset class (between $10 billion and $15 billion) without increasing any safety and soundness risks to the National Credit Union Share Insurance Fund (NCUSIF).”

As the agency finalizes this proposal, CUNA shared several suggestions:

• Closely monitor for any unintended consequences related to the proposed change—primarily increased risk to the NCUSIF—and adjust accordingly.
• Have sufficient training, expertise, and tools for examiners to perform consistent and efficient examinations across all regions and for all covered credit unions.
• Grandfather in tier I covered credit unions that are currently supervised by ONES.
• When utilizing the “reservation of authority” provision, NCUA should have a clearly demonstrated rationale for transferring a tier I credit union from its Regional Office to ONES prior to reaching the $15 billion asset threshold.
• Be mindful of any disconnect between NCUA examinations and Consumer Financial Protection Bureau (CFPB) examinations that may occur in light of increasing the ONES threshold above $10 billion.