CUNA supports NCUA’s commitment to continually reviewing its regulations, CUNA wrote in response to NCUA’s annual review of one-third of its regulations. The letter provides suggestions on how to streamline, clarify or otherwise improve regulatory requirements in the regulations covered by the review.

“As the NCUA is aware the cumulative regulatory burden on credit unions is near an all-time high. Therefore, 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 called on NCUA to:

• Allow cryptocurrency-related services as a pre-approved Credit Union Service Organization (CUSO) activity.
• Explore the ability of credit unions to invest additional capital in “credit union organizations” and consider a rulemaking that would authorize additional investment authority.
• Explore the possibility of further increasing residential and non-residential appraisals thresholds or abandoning them all together.
• Provide guidance on advertising on social media and consider adding advertisements posted to social media to the list of exceptions from the official advertising statement.
• Extend the credit union asset threshold for the 18-month examination cycle to $3 billion (up from the current $1 billion).
• Work with Congress to ensure credit unions are included in any deposit insurance reform.
• Revisit its regulations related to supervisory committee audits and verifications to scrutinize where unnecessary and/or duplicative requirements can be scaled back.

CUNA also highlighted its:

• Opposition to legislative changes aimed at establishing blanket NCUA oversight authority over CUSOs.
• Support for any legislative and regulatory changes to expressly include CUSOs for Federal Home Loan Bank membership and encourages the NCUA to support Federal Housing Finance Agency policy changes that would allow all CUSOs to be eligible for membership in FHLBanks.
• Strong support for NCUA’s proposed change to expand the definition of “qualified charity” to include section 501(c)(19) organizations; CUNA requested such a rulemaking last year.
• Support for the extension of an expired provision in the CARES Act related to the NCUA’s Central Liquidity Facility allowing corporate credit unions to act as agents for smaller (under $250 million in assets), non-CLF member, natural person credit unions.