CUNA supports NCUA’s budget process, raises some concerns

December 2, 2019

While CUNA supports aspects of NCUA’s proposed budget, particularly the transparency of the process, CUNA did raise several concerns in its comment letter submitted to the agency Monday. CUNA’s letter follows its presentation at NCUA’s Nov. 20 budget briefing.

“We commend the agency for continuing to provide comprehensive budget information as well as rationalization of the budget and agency expenditures in the context of a well-communicated strategic plan,” the letter reads. “Providing budget items in advance, holding an open briefing where stakeholders are invited to comment, and soliciting written comment is good public policy and reflects the agency’s commitment to government transparency.”

Specifically, NCUA’s proposed budget includes a 3.9% increase, which CUNA believes “compares favorably to increases in both headline inflation and credit union operating expenses.”

CUNA also noted concerns in the following areas:

  • Regional consolidation: While CUNA supports the focus on cost savings and efficiency in consolidating regions, it has resulted in some inconsistency in the interpretation and application of rules and regulations;
  • Examination cycle: An extended exam cycle is a helpful tool but should be expanded to more credit unions (i.e., the threshold should be increased to $3 billion);
  • Share insurance fund Normal Operating Level: CUNA supports the agency’s action last year to decrease the NOL to 1.38% but urges the board to ultimately reduce it back down to 1.30%; and
  • Expansion of the Office of Consumer Protection: While board member Todd Harper’s proposal may be well-intentioned, CUNA believes altering the agency’s risk-focused examination process and substantially increasing examination-related expenditures is not warranted at this time.

The board will vote on the final budget at its Dec. 12 meeting.