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August 3, 2008 -NASCUS responded to the National Credit Union Administration (NCUA) Regulatory Review for 2008 in an August 1 letter to the agency.
NASCUS focused its comments on rules that affect state-chartered, federally insured credit unions (FISCUs) and on how to streamline compliance with those NCUA Rules and Regulations. NASCUS suggests that all rules affecting federally insured credit unions should be reorganized and included in their entirety in Part 741, Requirements for Insurance.
In addition, NASCUS discusses several ways NCUA can enhance the distinction between its chartering and insurance roles and aid compliance with NCUA rules and regulations. NASCUS suggests that NCUA hold separate meetings, or alternatively, separate the regularly scheduled monthly board meeting into two parts recognizing NCUA’s dual responsibilities as the federal credit union regulator and administrator and insurer of the National Credit Union Share Insurance Fund (NCUSIF). With this format, it would be clear when the NCUA is considering rulemaking or changes affecting federal credit unions or federally insured credit unions.
Further, NASCUS recommends that NCUA include as a part of the “matters to be considered” section on the board agenda the parties to which the rule applies. Some NCUA rules affecting FISCUs are incorporated by reference in Part 741, which sometimes makes it difficult to understand how or if certain regulations affect FISCUs. NASCUS believes that this clarification will help credit unions better understand when a regulation affects them.
Lastly, NASCUS asks NCUA to consider expanding the ability of state regulatory agencies to apply for waivers from NCUA insurance rules for provisions not statutorily mandated for FISCUs. NASCUS suggests that Part 741 contain a general provision, applicable over matters where NCUA has discretionary rule making, which allows a state regulator to submit to NCUA a state rule that would substitute for any provision of Part 741 that is not statutorily mandated and does not increase the risk to safety and soundness. NASCUS believes this would promote efficiency in the examination and supervisory process.
The NASCUS comment letter can be viewed here on the NASCUS Web site.
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