CUNA Responds to NCUA Proposed Rules on M&A, Subordinated Debt, Loan Rate Ceiling

January 23, 2020

January 23, 2020
Washington, DC


Lauren Williams        
CUNA Communications        


CUNA Responds to NCUA Proposed Rules on M&A, Subordinated Debt, Loan Rate Ceiling

Credit Union National Association (CUNA) today released three statements following the National Credit Union Administration (NCUA) board meeting. A number of proposals were under consideration, including proposals on subordinated debt and credit union combination transactions, among other items. This is the board’s first meeting of 2020


Regarding Credit Union Combination Transactions
“As the specter of bank branch closures continues to threaten communities across the country with the prospect of becoming a banking desert, we absolutely stand behind credit unions reaching out to ensure that these communities retain access to local financial services. We look forward to reviewing the NCUA’s guidance on this topic, and offering our feedback on how to best equip credit unions to advance these communities.”  

Between 2004 and 2018, banks have closed over ten thousand branches, creating a net loss of 1,700 bank branches—as well as 86 new banking deserts—making it more difficult for U.S. consumers to access local financial institutions. CUNA maintains that consumers benefit by gaining access to strong, responsible community-focused financial services.

Regarding Subordinated Debt
“We appreciate the NCUA continuing to keep a critical eye on how stringent regulatory compliance standards affect credit unions’ ability to serve their members. We look forward to reviewing today’s proposal, and will engage with the NCUA on how to ensure that credit unions can remain the best financial partner for consumers across the country.”

In it’s June 2019 letter, CUNA noted that alternative capital has the potential to benefit numerous credit unions and allow them to continue to grow their operations. 

Regarding Federal Credit Union Loan Interest Rate Ceiling
“While it is critical that the board at least maintain the current cap of 18%, we’re pleased to learn the Board will examine the potential benefits that a floating interest rate cap can provide federal credit unions managing risk portfolios.”


Elizabeth Eurgubian
CUNA Deputy Chief Advocacy Officer & Sr Counsel


About CUNA:           
Credit Union National Association (CUNA) is the only national association that advocates on behalf of all of America’s credit unions, which are owned by 115 million consumer members. CUNA, along with its network of affiliated state credit union leagues, delivers unwavering advocacy, continuous professional growth and operational confidence to protect the best interests of all credit unions. For more information about CUNA, visit To find your nearest credit union, visit