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Comments on subordinated debt, bylaws proposals due in December

November 28, 2022

Comments on NCUA’s subordinated debt proposal and federal credit union bylaws proposal are among several proposals with comment deadlines in December.

NCUA’s bylaws proposal would amend the Federal Credit Union Act to reflect the Credit Union Governance Modernization Act, signed into law this year. It would update the federal credit union member expulsion process.

Comments are due to NCUA Dec. 2.

NCUA’s subordinated debt proposal would make two changes related to the maturity of Subordinated Debt Notes (Notes) and Grandfathered Secondary Capital (GSC):

  • Replace the maximum maturity of notes with a requirement that any credit union seeking to issue notes with maturities longer than 20 years to demonstrate how such instruments would continue to be considered ‘‘debt.’’
  • Extend the regulatory capital treatment of GSC to the later of 30 years from the date of issuance or January 1, 2052.

Comments are due to NCUA Dec. 5.

Comments are also due Dec. 5 on the Federal Housing Administration’s (FHA) request for information regarding small mortgage lending. FHA seeks public input regarding barriers to the origination of small mortgages in the FHA program.