Additional relief actions needed from NCUA, say CUNA, Leagues, CUs

March 24, 2020

CUNA followed up its March 12 letter to NCUA Tuesday with supplemental recommendations it has received through continued engagement with Leagues and credit unions. CUNA’s original letter detailed possible NCUA actions to alleviate the impact of the coronavirus disease (COVID-19) on credit unions and their members, and CUNA President/CEO Jim Nussle followed up with a call to NCUA leadership last week.

“As today’s economic environment is rapidly changing and bringing new challenges, CUNA appreciates the NCUA Board and staff willingness to promptly address feedback received from the industry. We  understand the necessity in communicating information to NCUA as we receive it, and we appreciate the agency’s openness and responsiveness to these efforts,” the letter reads. “Based on information CUNA received from state Leagues and credit unions in the last few days as COVID-19 continues to affect the economy and credit union members, we have the following additional recommendations on immediate actions NCUA can take to alleviate burden on the industry.”

The recommendations call on NCUA to:

  • Send a letter to Financial Accounting Standards Board (FASB) asking it to suspend implementation of its Current Expected Credit Loss (CECL) standard for at least one year, until January 2024, at the very minimum;
  • Expedite the finalization of its proposed rule increasing the threshold level below which appraisals would not be required for residential real estate-related transactions to $400,000; 
  • Publicly suspend all routine previously scheduled onsite examinations and data collections for at least 120 days, unless there is an immediate need;
  • Provide guidance regarding how credit unions should respond to COVID-19 related issues regarding real property inspections, and what arrangements can be made if property owners do not want to permit access to their property due to COVID-19 concerns;
  • Make a change to the Low-Income Credit Union (LICU) designation to count and include PO boxes in the LICU designation as LICU members in the same way that an address is included based on census tract data;
  • Base the LICU designation on an area’s unemployment, which would be another way for credit unions to offer critical financial services to Americans in need. The NCUA could allow a credit union to be designated a LICU for a certain fixed period of time after unemployment in the credit union’s field of membership reached the 10% threshold;
  • Update its “Frequently Asked Questions Regarding COVID-19, NCUA and Credit Union Operations” document as it makes changes to its policies and procedures;
  • Publish on the front page of its website, and distribute through social and other media channels, a “Frequently Asked Questions for Credit Union Members Affected by COVID-19” document. This document could include information on:
    • Deposit insurance for credit union accounts;
    • Safety of credit union deposits;
    • How members may contact the NCUA with any questions;
    • How funds can be wired to relatives or friends affected by COVID-19;
    • How personal financial information should be protected against fraudulent activity;
    • How members’ credit scores may be affected during the COVID-19 crisis;
    • What steps members may take to prevent identity theft; and
  • Any other guidance for credit union members.