Allow NCUA to grant PCA forbearance, CUNA writes

November 30, 2021

CUNA wrote a letter on Tuesday to the Senate Banking, Housing, and Urban Affairs Committee in response to the hearing entitled, “CARES Act Oversight of Treasury and the Federal Reserve: Building a Resilient Economy.” 

Aid from the Coronavirus Aid, Relief, and Economic Security (CARES) Act created questions about credit unions’ net worth ratios, casting a light on the NCUA’s statutory inflexibility to provide accommodations to credit unions that saw an influx of deposits. 

“As Congress considers additional pandemic recovery legislation, we encourage you to include language that allows NCUA, on a case-by-case basis, to provide forbear from Prompt Corrective Action (PCA) for credit unions impacted by the pandemic and which were otherwise healthy prior to the onset of the crisis. While credit unions entered the crisis extremely well-capitalized, the impact of the ensuing economic crisis has and will put stress on capital and, given credit unions’ limited ability to raise capital, the regulator could use additional tools.” 

CUNA also recommended Congress lift the member business loan (MBL) cap for one year following a national emergency, and encouraged Congress to expand credit unions’ field of membership.  

The letter also reiterated credit union concerns with the proposed IRS reporting requirements that could still be included in the Senate’s work on the Build Back Better Act.  

“This proposal represents an unprecedented overreach of the federal government into the everyday lives of virtually every American. And we are concerned that it could have a profoundly negative impact on the unbanked, the underbanked, communities of color, immigrants, and low- and moderate-income households to the extent that it would discourage financially vulnerable individuals from choosing to access mainstream financial services.”