NASCUS’ value proposition to credit unions
- NASCUS is the watchdog for the state credit union system
- State-chartered CUs and state regulators are passionate about preserving a viable state credit union system for the benefit of current and future credit union members. Individual CU or regulators cannot do this alone. We must raise our voices collectively to effectively persuade federal policymakers that are overreaching in their authority and stifling the state system.
- NASCUS is unique – our members are both state credit unions and state regulatory agencies. Both groups help shape NASCUS’ policy positions. NASCUS members – the regulators and the regulated – engage in extensive dialogue regarding our policy positions. Our policy positions are “informed by” the expertise and experience of both our credit union and regulator members. NASCUS believes a safe and sound credit union system is the product of a partnership between the regulators and the regulated. Sound supervision requires balancing the need for rules with the need for business flexibility. NASCUS’ positions are informed from feedback from both groups.
- NASCUS advocates on behalf of the state system and interacts with federal policy makers and “other influencers” including the NCUA, other federal agencies (FinCEN, Treasury, CFPB, etc.), Congress and the White House. NASCUS has had the opportunity to work with White House policy professionals in the past. For example with regard to NCUA Board appointments, and anticipates doing so going forward.
- NASCUS is a respected source for information and feedback on policy impact to the state credit union system.
- NASCUS actively opposes efforts to preempt state authority and infringe upon the ability of the states to empower and regulate their credit unions under state law. When federal regulators overstep their bounds, NASCUS pushes back on behalf of the state system. Examples include: Calls for increased transparency for NCUA’s budget and the OTR; recent impacts to derivatives authority; fiduciary duty; preserving the state specific MBL exception; the proposed home based credit union rule from NCUA; risk-based capita;, the propriety of supplemental capital.
- What is the NASCUS difference? The regulators’ perspective—this perspective gives NASCUS a unique advantage not held by credit union trade groups. NASCUS has a seat at the table with federal/state regulators that national credit union trade groups which allows NASCUS to interact on a peer level with federal regulators in a way others cannot. “Regulator to regulator discussions” allow for credible and frank dialogue from one policy maker to another. NASCUS CU members can make their case to a wide swath of the state system. And, that CU feedback, if on point, can influence how state regulators view issues for the benefit of the entire system and in turn inform the case state regulators make during peer to peer discussions.
- NASCUS is not impacted by potential conflicts that may arise while representing the interests of both state and federal credit union charters because NASCUS advocates solely on behalf of a safe, sound and viable state credit union system.