Exam process alterations unwarranted, PCA flexibility needed

October 13, 2021

CUNA followed up NCUA Chairman Todd Harper’s hearing before the Senate Banking, Housing, and Urban Affairs Committee with a letter to Harper regarding several issues discussed at the hearing. Harper, who was named chairman in January by President Joe Biden, was re-nominated by Biden for a full term.

“We appreciate your transparency in identifying your top policy priorities: capital and liquidity, consumer financial protection, cybersecurity, and diversity, equity, and economic inclusion,” the letter reads. “These priorities are also of utmost importance to CUNA, our member credit unions, and their consumer-members.”

CUNA also shared specific thoughts on NCUA actions, including requesting NCUA:

  • Extend the interim final rule providing Prompt Corrective Action (PCA) relief, as it is scheduled to expire in early 2022.
  • Provide further PCA relief by using its broad authority to define “total assets” and exclude certain additional assets from the net worth ratio.
  • Actively engage Congress to pursue changes to the Federal Credit Union Act to provide the board with additional tools to aid otherwise healthy credit unions that encounter crisis-induced PCA challenges.

CUNA also noted a response from Harper regarding credit unions and consumer protection, where he reiterated the call for the agency to conduct separate consumer compliance examinations for credit unions with at least $1 billion in assets.

“While your objective may be well-intentioned, CUNA and our members believe altering the agency’s risk-focused examination process and increasing examination-related expenditures is not warranted,” the letter reads. “There has been no supplementary evidence introduced or observed to suggest credit unions’ consumer compliance management has become a risk area warranting an increased expenditure of agency resources.”