Final Rule Summary: Joint Ownership Share Accounts (Part 745)
Prepared by NASCUS Legislative & Regulatory Affairs Department
March 2021
NCUA has issued a final rule amending its rules regarding what documentation the National Credit Union Share Insurance Fund (NCUSIF) may rely on to evidence joint ownership of a share account for separate share insurance coverage. The final rule amends § 745.8 to provide an alternative method to satisfy the membership card or account signature card requirement necessary for insurance coverage in the event the jointly signed membership cards cannot be produced by the credit union.
This rule applies to federally insured state credit unions (FISCUs) by reference in § 741.212.
The change mirrors one made in 2019 by FDIC for banks.
The provisions of this rule become effective March 26, 2021. The rule may be read in its entirety here.
Summary
As the Administrator of the NCUSIF, NCUA is authorized to promulgate regulations governing the payment of coverage to members in the event of the failure of a federally insured credit union (FICU). NCUA recognizes categories of accounts, and each category is eligible for the maximum share insurance coverage allowable by law.
Section 745.8 of the NCUA’s Rules & Regulations governs share insurance coverage for joint ownership accounts and provides that ‘‘qualifying joint accounts’’ will be insured separately from the joint co-owners’ individual accounts (if any). In general, “qualifying joint accounts’’ must satisfy two requirements:
- Each co-owner has personally signed a membership card or account signature card; and
- Each co-owner possesses withdrawal rights on the same basis.
The final rule amends § 745.8 to allow a FICU to use information contained in its account records to satisfy the signature card requirement proving joint ownership when the signature card or membership cards cannot be located. Examples of information that could prove co-ownership of the account include:
- Evidence that the FICU issued the means for accessing the account to each co-owner; or
- Evidence of usage of the share account by each co-owner.
Part 745.8(c) is amended to read as follows:
- 745.8 Joint ownership accounts * * * * *
(c) Qualifying joint accounts.
(1) A joint account is a qualifying joint account if each of the co-owners has personally signed a membership or account signature card and has a right of withdrawal on the same basis as the other co-owners. The signature requirement does not apply to share certificates, or to any accounts maintained by an agent, nominee, guardian, custodian or conservator on behalf of two or more persons if the records of the credit union properly reflect that the account is so maintained.
(2) The signature card requirement of paragraph (c)(1) of this section also may be satisfied by information contained in the account records of the federally insured credit union establishing coownership of the share account, including, but not limited to, evidence that the institution has issued a mechanism for accessing the account to each co-owner or evidence of usage of the share account by each co-owner.
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Final Rule Summary: Corporate Credit Unions (Part 704)
Prepared by NASCUS Legislative & Regulatory Affairs Department
March 2021
NCUA has issued a final rule to cohere the agency’s Part 704, Corporate Credit Unions with the 2020 final Subordinated Debt rule. Part 704 applies to state-chartered corporate credit unions by reference in § 741.206.
The final rule:
- Makes clear corporate credit unions may purchase natural person credit union subordinated debt
- Incorporates the definition of subordinated debt from the 2020 final rule into Part 704
- Requires corporate credit unions deduct from their Tier I capital calculation the amounts of any natural person subordinated debt in which they are invested
The provisions of this rule become effective January 1, 2022. The rule may be read in its entirety here.
Summary
NCUA’s final Subordinated Debt rule permits low-income designated credit unions, complex credit unions, and new credit unions to issue subordinated debt instruments for purposes of regulatory capital treatment. This final corporate credit union rule will govern how corporate credit unions invest in those instruments issued by natural person credit unions (NPCUs).
- What is NPCU Subordinated Debt?
NCUA’s Subordinated Debt rule defines NPCU subordinated debt as any debt instrument issued by a natural person credit union that is subordinate to all other claims against the credit union, including the claims of creditors, shareholders, and either the NCUSIF or the insurer of a privately insured credit union.
This definition is now incorporated into the definitions of § 704.2.
- May corporate credit unions purchase NPCU subordinated debt?
Yes. A corporate credit union’s ability to purchase NPCU subordinated debt is inherit in the corporate credit union’s lending authority because NCUA has characterized the issuance of subordinated debt as a borrowing for the NPCU. Because corporate credit unions’ current lending authority is sufficiently broad to include purchasing subordinated debt instruments NCUA is not making any changes to the regulatory text of § 704.
- What is the affect on a corporate credit union’s regulatory capital of purchasing NPCU subordinated debt?
Part 704 currently requires corporate credit unions to deduct from Tier 1 capital any investments in perpetual contributed capital and nonperpetual capital accounts that are maintained at other corporate credit unions. The final rule will treat NPCU subordinated debt in the same manner. To guard against systemic risk and the potential for cascading losses, NPCU subordinated debt purchased by a corporate credit union will be fully deducted from the corporate credit union’s Tier I capital.
Summary: NCUA 2021 Regulatory Review
Prepared by NASCUS Legislative & Regulatory Affairs Department
February 2021
The NCUA maintains a rolling review schedule that identifies 1/3 of the agency’s existing regulations for review each year and provides stakeholders an opportunity to comment. NCUA’s Regulatory Review is a not an exclusive list of NCUA rulemaking this year, the agency will also engage in discretionary rulemaking involving any provision it believes necessary.
NCUA’s 2021 Regulatory Review may be read here.
Comments on NCUA’s 2021 regulatory review are due to NCUA by August 16, 2021. NASCUS will file comments on the Regulatory Review. To discuss the 2021 NCUA Regulatory Review, please contact NASCUS at your convenience.
This year, NCUA will review the following 12 rules as part of the agency’s review:
- 748 Security Program, Report of Suspected Crimes, Suspicious Transactions, Catastrophic Acts and Bank Secrecy Act Compliance
Part 748 applies to FISCUs by way of reference in Part 741.214. The rule mandates compliance with the BSA, the creation of a written security program, and the creation of a program to safeguard member information.
- 749 Records Preservation Program and Appendices – Record Retention Guidelines; Catastrophic Act Preparedness Guidelines
Part 749 applies to FISCUs by way of reference in Part 741.215. NCUA’s record retention rule requires all federally insured credit unions (FICUs) to maintain a records preservation program to identify, store and reconstruct vital records in the event the credit union’s records are destroyed. Credit unions are required to maintain written policies and procedures for compliance with the rule.
- 750 Golden Parachute and Indemnification Payments
Part 750 applies to FISCUs by way of reference in § 741.224. The rule limits the ability of insured credit unions to indemnify senior officials being sanctioned for regulatory wrongdoing as well as providing excessive exit compensation to those officials.
- 760 Loans in Areas Having Special Flood Hazards
Part 760 applies to FISCUs by way of reference in Part 741.216. The rule requires FICUs to maintain a Flood Act compliance program.
- 761 Registration of Residential Mortgage Loan Originators
Part 761 applies to FISCUs by way of incorporation in Part 741.223. The rule now provides a cross reference to the CFPB’s Regulation G and mandating that mortgage loan originators be registered (or licensed if they work for a CUSO) with the Nationwide Mortgage Licensing System and Registry (NMLS).
- 790 Description of NCUA; Requests for Agency Action
Part 790 establishes NCUA’s various offices and regions as well as establishes procedures for public to request agency action.
- 791 Rules of NCUA Board Procedure; Promulgation of NCUA Rules and Regulations; Public Observation of NCUA Board Meetings
Part 791 governs NCUA conduct of business: from board meetings to rulemaking.
- 792 Requests for Information under the Freedom of Information Act and Privacy Act, and by Subpoena; Security Procedures for Classified Information
Part 792 governs NCUA’s records. The provision covers Freedom of Information Act requests, NCUA’s keeping of non-public records, NCUA information security, NCUA’s handling of subpoenas, and the Privacy Act.
- 793 Tort Claims Against the Government
This provision addresses litigating tort claims against NCUA.
- 794 Enforcement of Nondiscrimination on the Basis of Handicap in Programs or Activities Conducted by the National Credit Union Administration
Part 794 prohibits NCUA from discriminating on the basis of handicap.
- 796 Post-Employment Restrictions for Certain NCUA Examiners
Part 796 prohibits NCUA senior examiners from accepting employment with a FICU within 12 months of leaving service under certain circumstances.
- 797 Procedures for Debt Collection
This provision authorizes NCUA to collect certain debts owed to the United States by individuals and entities.
21-RA-04 HMDA Data Collection Requirements for Calendar Year 2021
February 2021
NCUA Regulatory Alert 21-RA-04 to provide additional HMDA filing information for credit unions meeting the following criteria and subject to the CFPB’s Regulation C for filing mortgage data on the credit union’s 2021 activities in March of 2022
- The credit union’s total assets as of 12/31/2020 exceeded $48 million;
- The credit union had a home or branch office in a MSA on 12/31/2020;
- The credit union originated at least 1 home purchase loan (other than temporary financing such as a construction loan) or refinanced a home purchase loan, secured by a 1st lien on a 1-4 unit dwelling during 2020; and
- The credit union originated at least 100 covered closed-end mortgage loans orat least 500 covered open-end lines of credit in each of the 2 preceding calendar years (2019 and 2020).
Credit unions meeting all 4 criteria must collect HMDA data during this calendar year to be submitted by March 1, 2022. A credit union that does not meet all 4 criteria is exempt from filing HMDA data in 2022 for mortgage loan applications processed in 2021.
HMDA Data Partial Exemptions
Section 1003.3(c) of the HMDA rule contains a list of partial exemptions from the filing requirements. NCUA Regulatory Alert discusses some of these exemptions and provides an illustrative chart showing an example of how partial exemptions are applied.
The HMDA filing requirements include 48 total data points. Of these, 26 data points are not required to be collected and reported if a transaction qualifies for a partial exemption (reducing reporting to 22 data points only for qualifying institutions).
More information on partial exemptions is available in Appendix F of the 2020 A Guide to HMDA Reporting: Getting It Right!.
Recording of Jan. 25, 2021 Solar Winds Breach Webinar
(members only)
The webinar focuses on the latest information related to how the SolarWinds Orion “breach” was carried out along with secondary risks related to the SolarWinds software. The webinar also discusses the threat landscape through the analysis of case studies and examples for public disclosures.
21-RA-03 Submission of 2020 Home Mortgage Disclosure Act Data
February 2021
NCUA Regulatory Alert 21-RA-03 informs credit unions subject to HMDA reporting requirements in calendar year 2020 that loan/application data must be submitted to the CFPB by March 1, 2021. The requirement applies to credit unions that:
- are located in metropolitan areas;
- engage in certain types and volume of residential mortgage lending; and
- had assets greater than $47 million as of December 31, 2019,
NCUA notes in the alert that the closed-end mortgage loan threshold increased from 25 to 100 effective July 1, 2020. Therefore, credit unions that originated fewer than 100 covered closed-end mortgage loans in 2018 or 2019 are not required to report any closed-end mortgage loan information for 2020.
Excluded transactions are listed in Section 1003.3(c) of Regulation C.
Submission Process for Data Collected in 2020
Credit unions must submit their HMDA data using the HMDA Platform. NCUA also notes:
- Credit unions should use a modern web browser, such as the latest versions of Google Chrome, Mozilla Firefox, Internet Explorer 11, Safari or Microsoft Edge when accessing the platform.
- The FFIEC has developed a loan/application formatting tool to help credit unions format data into the required pipe delimited text file (.txt) format.
- All edits must be addressed prior to submission of the HMDA data. Edit reports may be viewed and downloaded from the Platform.
- An authorized credit union representative must certify the accuracy of the submission on the Platform (emailed/fax certificates will not be accepted).
For more information:
Technical questions about reporting HMDA data collected in or after 2020 should be directed to [email protected].
NCUA reserves the right to assess CMP against credit union that fail to meet their applicable March 1, 2021 filing deadline.
21-RA-02 CFPB Publishes 2021 Threshold Adjustments Under Regulation C, Regulation Z and Regulation V
NCUA issued Regulatory Alert 21-RA-02 to inform credit unions on the CFPB’s threshold adjustments to Regulations C HMDA), Z (TILA) and V (FCRA). All three adjustments were effective on January 1, 2021.
- Regulation C Data Collection Asset-Size Exemption Threshold
The Reg C exemption threshold for 2021 increased to $48 million based on the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) in effect through November 30, 2020. Credit unions with assets of $48 million or less as of December 31, 2020 are exempt from collecting HMDA data in 2021.
- Regulation Z Escrows and Small Creditor QMs Asset-Size Exemption Threshold
The Reg Z escrow and small creditor qualified mortgages (QMs) asset-size exemption threshold increased to $2.23 billion. Credit unions with assets of less than $2.23 billion at the end of last year are exempt if other provisions of Reg Z are also met).
- Regulation V Credit Bureau Consumer Report Fee Ceiling
The ceiling on the fee a consumer reporting agency may charge for a consumer report in 2021 increased to $13.00, based proportionally on changes in the Consumer Price Index for All Urban Consumers (CPI-U). The ceiling does not affect the amount a credit union may charge its members or potential members, directly or indirectly, for obtaining a credit report in the normal course of business. Such cost must however be accurately represented in all advertising, disclosures, or agreements, whether written or oral.
Summary: Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations
Prepared by NASCUS Legislative & Regulatory Affairs Department
February 2021
On January 19, 2021, FinCEN, the Federal Reserve, NCUA, the OCC, and the FDIC issued answers to 7 frequently asked questions (FAQs) regarding suspicious activity reports (SARs) and other anti-money laundering (AML) considerations for financial institutions covered by SAR rules.
The FAQs may be read here.
Summary
Question 1 addressed whether financial institutions may keep an account open in response to a written request to do so from law enforcement even if the financial institution has identified suspicious or illegal activity. The FAQ notes that YES, financial institutions may choose to keep an account open in response to a written request from law enforcement if the institutions chooses. The FAQ recommends:
- the written request be specific and indicate both that the law enforcement agency has requested that the financial institution maintain the account, as well as the purpose and duration of the request.
- The financial institution consider maintaining documentation of “keep open” requests, including after a request has expired.
Institutions are still required to comply with all applicable BSA requirements, including requirements to conduct ongoing risk-based monitoring and filing of ongoing SARs.
Question 2 addressed whether a financial institution should file a SAR solely on the basis of receiving a grand jury subpoena or other law enforcement inquiries. The FAQs clarify that receipt of a law enforcement inquiry, such as a grand jury subpoena, does not by itself meet the SAR filing criteria. However, receipt of a grand jury subpoena or other law enforcement inquiry is pertinent information that should be incorporated into an institution’s overall assessment of risk and the risk profile for the relevant customer account and should cause the institution to review relevant account activity and transactions.
Question 3 addresses whether a financial institution is required to terminate a customer relationship following the filing of multiple SARs. The FAQs answer NO, there is no BSA regulatory requirement to terminate a customer relationship after the filing of a SAR or any number of SARs. The decision to maintain or close a customer relationship as a result of the identification of suspicious activity is a determination for a financial institution to make based on its risk tolerance and policies and procedures. An institution’s policies should establish criteria for when a review by senior management and legal staff is warranted to determine whether to maintain or terminate the customer relationship in light of elevated risk factors.
Question 4 addresses whether an institution is required to file a SAR based solely on negative news. The FAQs answer that NO, the existence of negative news related to a customer or other activity at an institution does not alone indicate that the SAR filing criteria have been met. An institution may review media reports, news articles and/or other references to assist in its performance of customer due diligence, as well as its evaluation of any transactions or activity it considers unusual or potentially suspicious and negative news may cause the institution to review customer activity as well as other related information, such as that of third parties with transactions involving the customer’s account.
Question 5 also addresses negative media alerts. The FAQs state that if an institution’s monitoring identifies multiple negative news alerts that are based on the same underlying events, the institution does not need to independently investigate each alert. If a particular alert contains new or different information that warrants further investigation or the news provides new information thru which to evaluate the activity or the customer, then an institution may rely on its policies to determine the prudence of investigating.
Question 6 addresses whether financial institutions need to repeat information in the SAR narrative that has already been included in other SAR data fields. The FAQs answers NO, information provided in other sections of a SAR does not need to be repeated in the narrative. Detail (such as subject identification data) that is reported in the appropriate SAR data fields does not need to be repeated in the SAR narrative, unless necessary to clearly describe the activity reported
Question 7 addresses whether institutions should file additional SARs on the same suspicious activity to accommodate narratives that are longer than the SAR narrative character limits. The FAQs answered NO, an institution reaching the SAR narrative character limit (20,000 characters) should review its narrative to ensure it contains only relevant information. Institutions can include an attachment to the SAR or note that supporting material is available as supporting documentation. Institutions can include a single comma-separated values (CSV) file with no more than one megabyte of data as an attachment to a SAR. Filers must retain all supporting documentation & business records for 5 years from the date of filing and should be made available to the appropriate authorities upon request.
CFPB Summary re: Seasoned Qualified Mortgage Loan Final Rule
12 CFR Part 1026
Prepared by the Legislative and Regulatory Affairs Division
February 2021
The CFPB is issuing this final rule to create a new category of QMs (Seasoned QMs) for first-lien, fix-rate covered transactions that have met certain performance requirements, are held in portfolio by the originating creditor or first purchaser for a 36-month period, comply with general restrictions on product features and points and fees, and meet certain underwriting requirements. The Bureau’s primary objective with this final rule is to ensure access to responsible, affordable mortgage credit by adding a Seasoned QM definition to the existing QM definitions.
The Final Rule becomes effective on March 1, 2021. The rule can be found here.
Summary
The Ability to Repay/Qualified Mortgage Rule (ATR/QM) requires a creditor to make a reasonable, good faith determination of a consumer’s ability to repay a residential mortgage loan according to its terms. Loans that meet the ATR/QM Rule’s requirements for QMs obtain certain protections from liability. The Bureau issued a proposal in August 2020 to create a new category of QMs – Seasoned QMs. The final rule defines Seasoned QMs as first-lien, fixed rate covered transactions that have met certain performance requirements over a seasoning period by the originating creditor or first purchaser, comply with general restrictions on product features and points and fees, and meet certain underwriting requirements.
Under the final rule:
- a covered transaction receives a safe harbor from ATR liability at the end of a seasoning period of at least 36 months as a Seasoned QM if it satisfies certain product restrictions, points and fee limits, and underwriting requirements and it meets performance and portfolio requirements during the seasoning period. Specifically, a covered transaction has to meet the following product restrictions to be eligible:
- The loan is secured by a first lien
- The loan has a fixed rate, with regular, substantially equal periodic payments that are fully amortizing and no balloon payments
- The loan term does not exceed 30 years and
- The loan is not a high-cost mortgage as defined by Section 1026.32(a)
- A creditor must consider the consumer’s DTI ratio or residual income, income or assets other than the value of the dwelling, and debts and verify the consumer’s income or assets other than the value of the dwelling and the consumer’s debts (using the same consider and verify requirements established for General QMs in the General QM Final Rule) for a loan to be eligible to become a Seasoned QM.
- A loan generally is eligible to season only if the creditor holds it in portfolio until the end of the seasoning period. There are several exceptions to this portfolio requirement that are similar to the exceptions to the Small Creditor QM portfolio requirement under the ATR/QM Rule. The final rule also includes an additional exception for a single transfer of a loan during the seasoning period. In the event of such a transfer, the final rule requires the purchaser to hold loan in portfolio after the transfer until the end of the seasoning period.
- A loan must meet certain performance requirements at the end of the seasoning period. Specifically, “seasoning” is available only for covered transactions that have no more than two delinquencies of 30 or more days and no delinquencies of 60 or more days at the end of the seasoning period. Funds taken from escrow in connection with the covered transaction and funds paid on behalf of the consumer by the creditor, servicer, or assignee of the covered transaction (or any other person acting on their behalf) are not considered in assessing whether a periodic payment has been made or is delinquent for purposes of this final rule. Creditors can, however, generally accept deficient payments, within a payment tolerance of $50, on up to three occasions during the seasoning period without triggering a delinquency for purposes of this final rule.
- The “seasoning period” is defined as a period of 36 months beginning on the date which the first periodic payment is due after consummation. Failure to make full contractual payments does not disqualify a loan from eligibility to become a Seasoned QM if the consumer is a temporary payment accommodation extended in connection with a disaster or pandemic-related national emergency, as long as certain conditions are met.
- A qualifying change is defined as an agreement entered into during or after a temporary payment accommodation extended in connection with a disaster or pandemic-related national emergency that ends any preexisting delinquency and meets certain other conditions to ensure the loan remains affordable.
Request for Information: NCUA Communications & Transparency
Prepared by NASCUS Legislative & Regulatory Affairs Department
January 2021
NCUA is seeking comments and information on how the agency can improve its communications to stakeholders, improve efficiency of NCUA’s presentation and reporting of information to the public, and reduce the burden on stakeholder’s consumption of NCUA communications.
The NCUA Request for Information may be read here. Comments are due to NCUA March 9, 2021.
Summary
The NCUA is seeking input on how to make its communications with federally insured credit unions more effective, consistent, and clear to minimize unnecessary regulatory and operation burdens as much as possible. The RFI solicits comments on how NCUA can maximize efficiency and minimize burdens associated with obtaining information on federal laws, regulations, policies, guidance, and other materials relevant to FICUs.
The RFI is open ended and asks for all constructive suggestions to improve NCUA communications. NCUA provides a list of communications, including:
REGULATIONS, POLICIES, PROCEDURES, AND GUIDANCE
- Federal Register: The NCUA publishes proposed and final rules, requests for information, and other notices, including statements of policy and certain guidance or interpretations in the Federal Register.
- Unified Agenda: Biannually through the Unified Agenda process, NCUA publishes an agenda of regulations to inform the public of its regulatory actions and to enhance public participation in the rulemaking process.
- Letters to Credit Unions: Provide guidance on specific NCUA policies and procedures, compliance, governance, and other timely issues that affect all federally insured credit unions.
- Letters to Federal Credit Unions: Provide guidance on specific NCUA policies and procedures, compliance, governance, and other timely issues that affect only credit unions with a federal charter.
- Risk Alerts: Detail practices or external threats that potentially are significant risks to the safety and soundness of the credit union system.
- Regulatory Alerts: The NCUA uses regulatory alerts to provide guidance on rules and regulations from other agencies that credit unions must comply with.
- Supervisory Letters: While geared towards the NCUA’s examiners to provide instructions and information on a range of supervisory and regulatory issues, Supervisory Letters are posted on the NCUA’s website for the benefit of credit unions and the public.
- Accounting Bulletins: Accounting Bulletins provide guidance and instructions on how changes in generally accepted accounting principles and other regulatory initiatives affect how credit unions report these items in their financial statements.
- Corporate Credit Union Guidance Letters: NCUA ONES issues letters to inform corporate credit unions about specific NCUA policies and procedures, compliance, governance, and other timely issues.
- Consumer Financial Protection Updates: Announce new activity on consumer compliance laws, regulations and guidance.
EXAMINATION MANUALS AND GUIDES
- Online Examiners Guide
- National Supervision Policy Manual
- Chartering & Field of Membership Manual
- Fair Lending Guide
- Federal Consumer Financial Protection Guide (FAQs)
NCUA BOARD MEETINGS & ASSOCIATED DOCUMENTS
- Board Meeting Agendas
- Board Action Memorandum
- Board Action Bulletins
NEWS AND UPDATES
- Press Releases
- Speeches
- Testimony
- Statements
- Annual reports to Congress
- Events Calendar
INDUSTRY DATA, EDUCATIONAL MATERIALS, AND OUTREACH
- Credit Union and Corporate Call Report Data
- Quarterly State Map Reviews
- Industry at a Glance
- Chartering and Merger Activity Reports
- NCUA Videos, Webcasts, Webinars General Communications
- CUSOs at a Glance
- Manuals & Guides
GENERAL COMMUNICATIONS
- gov website and MyCreditUnion.gov
- Social Media (such as Twitter, Facebook, LinkedIn, and YouTube)
- NCUA Express Email Subscriptions
In addition to general comments, NCUA seeks specific comments on the following questions:
- The NCUA issues, or has issued, regulatory and supervisory guidance under a variety of different letterheads, including Letters to Credit Unions, Letters to Federal Credit Unions, Corporate Credit Union Guidance Letters, Accounting Bulletins, Risk Alerts, Regulatory Alerts, Consumer Financial Protection Updates, and Supervisory Letters. Is this practice effective? Should the agency consider consolidating its supervisory guidance into fewer letterheads?
- How effective are the NCUA’s current forms of communication, such as press releases, social media content, and email distributions? Which of these are the most or the least effective? Are there other methods of communication the NCUA should consider?
- Which communications vehicles are best suited for informing federally insured credit unions about new policy initiatives, laws and regulations, guidance, background or educational materials, news and other updates?
- How appropriate is the timing and frequency of the NCUA’s communication?
- Is it clear to federally insured credit unions which of the agency’s communication is supervisory in nature and which is purely informational?
NCUA also seeks feedback on Improving its Websites and Online Resources:
- How can the NCUA improve the NCUA.gov and MyCreditUnion.gov websites? Does the website search function provide helpful and relevant results? What aspects of the NCUA.gov and MyCreditUnion.gov websites are the most helpful?
- How often do you access the financial performance, chartering and merger data available on NCUA.gov? Is the current format useful to you? How can NCUA improve the presentation of data online?
- What other financial, business, or economic data websites do you use? What do you like about how they present their financial or economic data? What features should the NCUA consider when improving its presentation of financial performance and other data to stakeholders online?