NASCUS Issues Comments on Interim Final Rules for Asset Thresholds and Central Liquidity Facility

May 25, 2021

NASCUS Issues Comments to NCUA on Interim Final Rules for Asset Thresholds and Central Liquidity Facility

 NASCUS has submitted two comment letters to the National Credit Union Administration (NCUA) regarding proposed changes to the Interim Final Rules on Asset Thresholds and Central Liquidity Facility (CFL).

NASCUS supports the implementation of the interim rule on Asset Thresholds to mitigate transition costs for federally-insured credit unions (FICUs) related to the pandemic and the application of NCUA capital planning and stress testing rules. Furthermore, NASCUS believes that good cause exists for the issuance of this regulatory relief. This interim rule specifically allows a FICU to use March 31, 2020, financial data to determine whether the institution is subject to capital planning and stress testing requirements.

Given that the current calendar benchmark for determining ONES’ supervisory Tiers was quickly approaching, an immediate effective date was necessary to minimize confusion for credit unions approaching a $10 billion threshold or determining which stress test Tier was applicable to them.

As NASCUS previously noted in related COVID-19 responses, the unprecedented and volatile nature of the pandemic’s effect on both the economy and the financial services’ sector justifies expediting regulatory relief to facilitate credit unions’ pandemic response.

“Many credit unions have experienced a surge in deposits during the pandemic and some level of post-pandemic run-off is expected. Utilizing March 2020 data is a practical way to avoid subjecting credit unions to the additional compliance costs associated with the stress testing Tiers that would, but for the pandemic inflation of their balance sheets, not otherwise have qualified for stress testing under Part 702 at this time.”

As it applies to Central Liquidity Facility (CLF), this rule would amend NCUA Rules and Regulations Part 725, Central Liquidity Facility, to cohere with statutory changes made to the CLF resulting from the enactment of the Consolidated Appropriations Act.

NASCUS supports the changes to the CLF, and we continue to urge the NCUA to seek permanent enhancements to the CLF’s ability to serve the credit union system. The CLF remains an important source of liquidity for its credit union members and system as a whole. This includes:

  • Increasing the CLF’s borrowing authority
  • Permitting corporate credit unions to borrow for their own needs
  • Matching an agent’s stock subscription obligation to the agent’s members that wish to borrow
  • Making it easier for credit unions to join and withdraw from the CLF

Giving the CLF broader leeway to approve borrowings substantially contributes to the safety and soundness of the credit union system. Allowing these improvements to sunset until the next economic crisis would be a lost opportunity.

“We concur with the issuance of this proposal as an interim final rule. Particularly in this case, where NCUA’s changes are cohering to statutory changes made by Congress, making an exception to the public policy of advance notice and comment dictated by the Administrative Procedure Act is compelling.”

The copies of both NASCUS comment letters are available on the NASCUS website at:


CONTACT: Amanda Tuckey, Sr. Director, Communications and Marketing, NASCUS [email protected]

NASCUS is the national association that advocates for a strong and healthy state credit union system, and whose members include state regulatory agencies, credit unions, credit union leagues, and organizations that support the state credit union system.


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