July 6, 2020
Secretary of the Board
National Credit Union Administration
1775 Duke Street
Alexandria, VA 22314
Re: NASCUS – Comments on Proposed Rule Joint Ownership Share Accounts (RIN 3133-AF11)
Dear Mr. Poliquin:
The National Association of State Credit Union Supervisors (NASCUS) submits the following comments in response to the National Credit Union Administration’s (NCUA’s) request for comments on RIN 3133-AF11, a Proposed Rule amending the agency’s share insurance regulation § 745 related to joint ownership share accounts. The Proposed Rule would amend § 745.8 to provide an alternative method to satisfy the membership card or account signature card requirement necessary for insurance coverage by allowing information contained in the credit union’s account records to establish proof of joint ownership. The proposed change would bring NCUA’s share insurance rules in line with joint ownership account rules finalized by the Federal Deposit Insurance Corporation in 2019.
NASCUS supports this rulemaking. Providing federally insured credit unions flexibility in satisfying the signature card requirement with information in the account records acknowledges that account opening practices have evolved substantially since 1971. Furthermore, these proposed changes maximize the opportunity for legitimate account holders to establish the full share insurance coverage to which they are entitled.
In the Supplemental Information, NCUA explicitly notes that the two examples of evidence included in the proposed change, that the credit union has issued means to access the account to both individuals or both individuals had conducted transaction, were not intended “to define the only form of evidence” that would satisfy the signature requirement. To minimize the opportunity for confusion in the future, when credit unions or examiners may be referencing the regulations without the benefit of the Supplemental Material, we recommend NCUA consider a modest change to proposed § 745.8(c)(2). By replacing “such as” with the phrase “including, but not limited to,” before the word “evidence” NCUA can make clear on the face of the regulation that other evidence in the account records may be sufficient to establish qualifying joint ownership of a share account.
Thank you for the opportunity to submit comments on proposed changes to § 745.8. We would be happy to discuss our comments in detail or provide additional information at NCUA’s convenience.
– signature redacted for electronic publication –
Executive Vice President
 NASCUS is the professional association of the nation’s 45 state credit union regulatory agencies that charter and supervise over 2,000 state credit unions. NASCUS membership includes state regulatory agencies, state chartered and federally chartered credit unions, and other important stakeholders in the state system. State chartered credit unions hold nearly half the $1.6 trillion assets in the credit union system and are proud to represent nearly half of the 122 million credit union members.
 NCUA Proposed Rule: Joint Ownership Share Accounts, 85 Fed. Reg. 109, at 345455 (June 5, 2020).
 84 FR 35022 (July 22, 2019).
 85 Fed. Reg. 109, at 345456 (June 5, 2020).