Staff training key to mitigating compliance risk

CUNA provides suggestions to improve NCUA speaker request forms

October 27, 2023

CUNA provided suggestions on how to improve NCUA’s speaker request forms in comments filed in relation to an Office of Management and Budget (OMB) request on the forms. NCUA currently accepts requests for board members and staff to participate in speaking engagements via request forms on the agency’s website.

The data collection in question involves NCUA requesting approval from the OMB for a new information collection related to the two forms.

“Regulated credit unions’ ability to provide feedback to their federal regulator is of critical importance. A consistent, open dialogue is beneficial for both the NCUA and the credit unions it supervises and insures. It not only enables credit unions to bring emerging concerns to the attention of the agency’s leadership but also allows the agency to be more efficient and effective,” the letter reads. “Outside of the formal rulemaking and examination process, it is important for stakeholders and credit unions to be able to easily inform the agency about local trends and the impact of the agency’s actions on member service.

Maintaining a standardized process by which to request meetings with the agency helps ensure requesting parties have sufficient information on how to pursue direct meetings with Board and staff members,” it adds.

Specific to the OMB request, CUNA agrees with NCUA’s assessment of the per response burden estimate of fifteen minutes per request, which CUNA feels is appropriate.

CIUNA also offered several ways to improve the process, suggesting NCUA:

  • Streamline existing request forms should be to ensure all fields are relevant to certain meeting requests.
  • Detail both in a written communication to credit unions and on its website exactly what is required in order to request a meeting with agency staff.
  • Add a method to provide updates on the status of each request, for example, contact information for agency staff included in the automatic response generated when a request is submitted.
  • Share aggregate information regarding the number of meeting requests and meetings granted, including whether at the Board or staff level—and possibly the department or division in which the staff member works.