TDR extension, RBC delay among CUNA recommendations to NCUA

June 30, 2020

CUNA continued its ongoing, pandemic-related engagement with NCUA with a letter to Chairman Rodney Hood Monday containing policy recommendations and comments.  

CUNA has been in regular contact with NCUA board members and staff throughout the pandemic to discuss actions to help credit unions increase service to affected members.  

Recommendations include asking NCUA to: 

  • Extend the Troubled Debt Restructuring (TDR) exemption created by the CARES Act through at least the end of 2021; 
  • Allow interest to be capitalized on consumer mortgage loans in connection with a loan modification made during the time of the pandemic, an approach consistent with Fannie Mae and Freddie Mac requirements; 
  • Delay implementation of the risk-based capital rule to, at the earliest, January 2023, or forego the initiative altogether; 
  • Reconsider and approve its tabled overdraft interim final rule that would have permitted credit unions to adopt reasonable, flexible policies for members to resolve overdrawn accounts; and  
  • Remove the requirement that a consumer be a credit union member for one month before receiving a Payday Alternative Loan (PAL) I and provide credit unions guidance on working with financially distressed PAL borrowers.