Ahead of SBC hearing, CUNA commends NCUA and seeks add’l policy changes

May 12, 2020

May 12, 2020 
Washington, DC 
Lauren Williams 
CUNA Communications 

Credit Union National Association (CUNA) yesterda sent a letter to the Senate Banking Committee (SBC) ahead of its hearing with federal financial regulators. National Credit Union Administration (NCUA) Chairman Rodney Hood is expected to testify before the committee. The letter commends the swift action NCUA has taken to assist credit unions working with members affected by the COVID-19 pandemic but also recommends additional policy changes.  

“Uncertainty has been pervasive since the outset of the COVID-19 pandemic and continues to be one of the greatest challenges facing us now. It is impossible to forecast precisely the duration of the crisis or the depth of its economic and financial impact,” CUNA President/CEO Jim Nussle wrote. “For credit unions that need to remain open to serve all their members, and in a position to help those in need, the uncertainty factors into every decision they make.” 

NCUA has allowed military personnel to count toward the low-income credit union designation, issued guidance on remote and virtual board meetings, implemented a rule to relax appraisal requirements, acted quickly to expand the Central Liquidity Facility and other actions since the onset of the pandemic.   

CUNA highlighted several areas where NCUA and Congress should take action to ensure that credit unions remain positioned to serve their members during the crisis and into economic recovery:

  • Review its existing Prompt Corrective Action (PCA) regulations and offer forbearance to credit unions that may temporarily fall between the 6% and 7% net worth leverage ratio;
  • Further delay implementation of the risk-based capital rule to, at earliest, Jan. 1, 2023;  
  • Understand and consider credit union’s good-faith efforts regarding Regulation B (Equal Credit Opportunity Act) notices for new credit products intended to assist members during the pandemic;  
  • Issue an interim final rule on Payday Alternative Loans (PALs) to ensure credit unions have the flexibility to meet members’ needs during the pandemic;  
  • Expand the borrowing ability of the Central Liquidity Facility to 25 times the paid in capital, extend the expanded borrowing authority until the end of 2021 and make permanent the ability of corporate credit unions to act as agents for credit unions;
  • Temporarily reduce the level at which credit unions are considered well capitalized from a net-worth ratio of 7% to 6% and adequately capitalized from 6% to 5% during the pandemic; and 
  • Exempt credit union business loans from the member business lending cap until one year after the end of the COVID-19 emergency declaration. A House bill has introduced to accomplish this, and a Senate bill has been announced.