CUNA submitted its written comments on NCUA’s proposed 2023-24 budget Friday. The written comments follow CUNA Deputy Chief Advocacy Officer Jason Stverak’s presentation Oct. 19 at the agency’s public budget briefing.

CUNA thanked NCUA for providing comprehensive budget information and the rationalization and urged the agency to continue the same level of transparency and engagement.

“The NCUA’s proposed 2023 budget reflects an 8.1% increase in expenditures overall compared to the 2022 Board-approved budget,” the letter reads. “Although the requested Capital Budget and Share Insurance Fund Administrative Budget reflect declines, the Operating Budget (which accounts for 94% of total agency expenditures) reflects an increase of 9.6%.

“While an increase is unsurprising in today’s economic environment, CUNA is concerned with the extent of this proposed increase,” it adds, since the increases come against “a backdrop of elevated financial pressure” for credit unions.

CUNA also:

• Supports the addition of certain positions, including a new one for the Office of Minority and Women Inclusion and special examiners at the regional office level, but question the need for a net increase of 10 specialist examiners.
• Urges NCUA to continue to seek to contain travel costs by use of offsite examination procedures and virtual options for training.
• Continues to have significant concern around any expansion in consumer protection examination activity, as CUNA members believe altering the agency’s risk-focused examination process and substantially increasing consumer examination-related expenditures is not warranted.
• Urges NCUA to extend the credit union asset threshold for the 18-month examination cycle from $1 billion to $3 billion.
• Strongly objects to any suggestion that the NCUA may need to charge a premium in the near future and/or that statutory changes to the share insurance fund funding guidelines are needed.
• Suggests the agency give credit unions a “more obvious” role in the process of improving examinations, specifically, to develop and conduct ongoing, confidential examination staff satisfaction surveys distributed to credit unions after each examination.
• Urges NCUA to collaborate thoroughly with the industry before any concrete steps are taken on climate-related financial risk.