EGRPRA letter urges rule format change

CONTACT: Patrick Keefe, NASCUS Communications/703-528-5974,

NASCUS letter on ‘EGRPRA’ notes current rule structure cumbersome, confusing

ARLINGTON, VA — Incorporation of all share insurance rules in one place, prudent diversification of corporate credit union rules, clarification of fidelity bond rules and acknowledgement that some state credit union boards may not meet monthly are all addressed in the NASCUS comment letter to NCUA on the agency’s Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA) review.

As NASCUS pointed out in its letter, filed today (Sept. 22), NCUA is not statutorily required to engage in EGRPRA review, but has elected to participate in the process by conducting an independent review that is “consistent and comparable” to the federal banking agencies process, and which takes into account the “unique circumstances of federally insured credit unions and their members.”

In its letter, NASCUS commends the agency for voluntarily participating in the review process. However, NASCUS made a number of suggestions for changes – in particular, to ease the regulatory burden on federally insured, state-chartered credit unions by changing the format of agency rules to incorporate in one place all rules covering share insurance.

“The current structure of NCUA’s Rules and Regulations is unnecessarily cumbersome and confusing for FISCUs and examiners alike,” NASCUS wrote. “NCUA could erase any confusion, and ease regulatory burden, by systematically reorganizing its Rules and Regulations to provide federal and state examiners, and FISCUs, a consolidated chapter of applicable insurance regulations.

In other comments, NASCUS:

  • Cited its concern that the current regulatory framework for the corporate system is too homogenized, and recommended “prudent diversity” within the corporate system, particularly with regard to state charters. “NCUA’s corporate credit union rule should provide for diversity of regulation at the state level for state-chartered corporate credit unions,” NASCUS wrote. “Such a provision could be modeled after existing NCUA share insurance provisions for natural person credit unions that allow for state-specific rules.”
  • Urged the agency to clarify what fidelity bond coverage rules apply to FISCUs. “Rather than incorporate by reference, NCUA should establish in § 741.201 the fidelity bond coverage requirements for FISCUs,” the association wrote.
  • Advocated that the agency recognize that not every state requires monthly meetings of credit union board, and adjust its rules accordingly for reporting purposes. “In some states, credit union boards meet every other month,” NASCUS wrote. “NCUA should revise guidance to provide that notification at the next board meeting satisfies the requirement. Allowing credit unions to sync their reporting to board meetings, rather than monthly, will help ensure boards focus on the information presented while providing credit unions regulatory relief by potentially reducing the paperwork of preparing reports for non-board meeting months.”


NASCUS comment letter/Regulatory Review Pursuant to the EGRPRA (Sept. 2015)

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The National Association of State Credit Union Supervisors (NASCUS) is the primary resource and voice of the state governmental agencies that charter, regulate and examine the nation’s state-chartered credit unions. NASCUS membership is made up of state-chartered credit unions, state regulators and other supporters of the state credit union system. NASCUS is the only organization dedicated to the defense and promotion of the state credit union charter and the autonomy of state credit union regulatory agencies.

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