News stories tagged comment letter
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Comment Letter to Appraisal Subcommittee
March 14, 2022 — The National Association of State Credit Union Supervisors (“NASCUS”) submitted a letter in response to the Appraisal Subcommittee (ASC) of the Federal Financial Institutions Examination Council...
Comment letter urges focus on risks from consolidation, climate change rules
(Jan. 28, 2022) While acknowledging that industry consolidation and regulation related to climate change are two risks NCUA should consider in the context of its five-year strategic plan, NASCUS wrote to...
BRIEFLY: 4 job openings in MA; CFPB seeks info on ‘junk fees;’ FDIC insurance director to retire; Agency selects new CLF president
(Jan. 28, 2022) Four new positions are being filled by the MA Division of Banks, the agency said this week. The MA openings include those for consumer protection examiner I...
Coordination among regulators crucial on digital assets, letter argues
(Oct. 29, 2021) Coordination with state and other federal regulators on regulation of decentralized finance (DeFi) and other emerging uses of digital assets is crucial to avoid conflicting rules and...
Sub debt amendment OK, but other changes needed
(Oct. 29, 2021) Now is the time to consider additional changes to the new subordinated debt rule – rather than adopt just one change to the rule — to ensure...
CCULR OK, but some considerations needed, NASCUS writes
(Oct. 22, 2021) The state system supports the NCUA proposed rule establishing a “complex credit union leverage ratio” (CCULR), as well as a quick implementation of a final regulation, but...
Reg review letter urges reorganizing rules
(Aug. 20, 2021) Reorganizing its rules to lessen confusion over application of anti-money laundering rules, and working with state regulators to implement those rules, are among the recommendations made by...
NASCUS: NCUA approach to NOL must accept tie between OTR, budget
(July 30, 2021) Any discussion about the normal operating level (NOL) of the federal credit union share insurance fund must acknowledge that the actual equity ratio of the fund is...
Letters support asset reporting threshold, CLF rules
(May 28, 2021) Comment letters on NCUA’s interim final rules on asset thresholds for reporting purposes, and for conforming existing NCUA’s Central Liquidity Facility rules with new statutes, were submitted...
Key comments: Opposition to provisions of RBC simplification proposal
(May 14, 2021) Two significant comment letters were submitted this week by the state system, on simplification of risk-based capital requirements and on adding an “S” for sensitivity to market...
Key comments: Support for adding ‘S’ for ‘sensitivity’ to exam rating system
(May 14, 2021) Moving expeditiously on adding a “market risk sensitivity” component to the credit union examination system – that is, adding an “S” to “CAMEL” – would better align...
States need same ‘beneficial ownership’ info too
(May 7, 2021) State regulators must have access to the same “beneficial ownership” information that federal agencies will have under legislation adopted last year, and made available through a database,...