The cumulative regulatory burden on credit unions is near an all-time high, though it has slowed recently, CUNA wrote to NCUA Monday. CUNA’s comments were sent in response to NCUA’s annual review of one-third of its regulations, this year’s covered parts 700 to 710.

“We urge the NCUA to promulgate new or expand existing rules only if such rules are clearly warranted based on a compelling need,” the letter reads. “Similarly, the agency should strongly consider the current regulatory burden on credit unions as it proceeds with this and future regulatory reviews.”

CUNA also recommends NCUA:

• Eliminate the current 2.5 million population limit for a “well-defined local community” for field of membership purchases, or at least raise it to $10 million.
• Be mindful of potential of issues developing a member expulsion rulemaking based on the enactment of the Credit Union Governance Modernization Act.
• Increase the threshold for federal credit unions to be exempt from an operating fee to $10 million (up from the current $1 million).
• Adopt its proposed rule on overdraft cure period, which a 45-day limit and replaced it with a requirement that the written policy must establish a specific time limit for a member cover each overdraft. This proposal has been pending for more than two years.

CUNA’s letter covers other NCUA regulations, including Loans and lines of credit to members; loan participations; designation of low-income status; and Prompt Corrective Action relief.

CUNA also notes the process for seeking comments on regulations as part of the review could be improved, including additional clarity on which areas are already subject to proposed changes or recent modifications.