NCUA Proposed Rule Summary: Federal Credit Union Bylaws Relating to Expulsion of a Member
Read NASCUS Legislative and Regulatory Affairs Department Summary Here
September 27, 2022
During the September 22, 2022, NCUA Board Meeting, the Board approved for publication and comment a proposed rule providing bylaw amendments that would allow additional authority for FCUs in the expulsion of members for cause. The proposed rule seeks to incorporate legislative changes resulting from the March 15, 2022, effective Credit Union Governance Modernization Act of 2022 (Governance Modernization Act) which ordered NCUA to develop policy by which a FCU member may be expelled by a two-thirds vote of a quorum of the FCU’s board of directors.
The deadline to submit a comment is December 2nd, 2022. The proposed rule may be read in its entirety here.
Notice of Proposed Rulemaking and Request for Comment
NCUA: Subordinated Debt
Read NASCUS Legislative and Regulatory Affairs Department Summary Here
October 5, 2022
At the September 22, 2022, NCUA Board meeting, the Board approved for comment a proposed rule that would amend the Subordinated Debt rule (the Current Rule), which the Board finalized in December 2020 with an effective date of January 1, 2022. The proposal would make two changes related to the maturity of Subordinated Debt Notes and Grandfathered Secondary Capital (GSC).
The proposed rule also includes four other minor modifications to the current subordinated debt rule. The proposed rule in its entirety can be found here. Comments are due December 5, 2022.
MEMBER BENEFIT: Click here to read the NASCUS summary proposed policy.
Joint Policy Statement Summary: Prudent Commercial Real Estate Loan Accommodations and Workouts
The Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), and National Credit Union Administration (NCUA) (the agencies), in consultation with state bank and credit union regulators, are inviting comment on an updated policy statement for prudent commercial real estate loan accommodations and workouts, which would be relevant to all financial institutions supervised by the agencies. This updated policy statement would build on existing guidance on the need for financial institutions to work prudently and constructively with creditworthy borrowers during times of financial stress, update existing interagency guidance on commercial real estate loan workouts, and add a new section on short-term loan accommodations. The updated statement also would address relevant accounting changes on estimating loan losses and provide updated examples of how to classify and account for loans modified or affected by loan accommodations or loan workout activity.
MEMBER BENEFIT: Click here to read NASCUS’s summary of the proposed rule.
Proposed Rule: Cyber Incident Notification Requirements for Federally Insured Credit Unions
Due to the increased frequency and severity of cyberattacks on the financial services sector, the NCUA Board is proposing to require a federally insured credit union that experiences a reportable cyber incident to report the incident to the NCUA as soon as possible and no later than 72 hours after the federally insured credit union reasonably believes that it has experienced a reportable cyber incident. This notification requirement provides an early alert to the NCUA and does not require credit unions to provide a detailed incident assessment to the NCUA within the 72-hour time frame.
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 (FFIEC) proposal to amend existing rules of practice and procedure governing temporary waiver proceedings.
The ASC’s proposed amendments are intended to provide greater transparency and clarity to temporary waiver proceedings pursuant to Section 1119(b) of Title XI of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989. A properly calibrated and equitable appraisal waiver process is essential to mitigate the dire effects that a regional scarcity of qualified appraisers can have on the provision of credit to consumers related to real estate transactions.
NASCUS welcomes efforts to enhance the waiver process and we commend the ASC for undertaking this important initiative. However, as discussed in the comment letter, the changes as proposed would likely diminish the practical effectiveness of the Section 1119(b) appraisal waiver process rather than strengthen it.
Click here to read this comment letter in full.
(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 (depository institutions); depository institution supervision manager; regional field manager of risk management examinations; and information technology examiner I. For details on each of the positions, see the link below … Reduction of “junk fees” charged by banks and financial companies is the aim of an initiative announced this week by CFPB. The bureau said its research has found areas where back-end fees (such as “resort fees” and “service fees”) obscure the “true cost” of a product and undermine a competitive market. Two examples the agency provided include more than $14 billion in “punitive” late fees charged by major credit card companies in 2019 and more than $15 billion in overdraft and non-sufficient funds (NSF) fees charged that same year. The agency announced a request for public comment for input that would help shape the agency’s rulemaking and “guidance agenda,” including future enforcement priorities … Diane Ellis, director of the division of insurance and research for the FDIC will leave the agency on May 31, the agency said this week, completing a 34-year career at the agency. She has served as director since 2013, when she was appointed to oversee the economic, banking, and policy research program and management of the agency’s Deposit Insurance Fund (DIF), the FDIC said … Effective Monday, Anthony Cappetta is the new president of the NCUA Central Liquidity Fund (CLF), the lender for credit unions that have unusual or unexpected liquidity shortfalls. Cappetta, a 30-year U.S. Army veteran, was named CLF vice president in 2019. He joined the agency in 2014 as director of the NCUA Guaranteed Notes division in the agency’s Office of Examination and Insurance. Before joining NCUA, the agency said, he served in leadership roles at several hedge funds and banks.
LINKS:
NASCUS Career/Job Postings webpage
Consumer Financial Protection Bureau Launches Initiative to Save Americans Billions in Junk Fees
FDIC Announces Retirement of Diane Ellis, Director of the Division of Insurance and Research
Anthony Cappetta Appointed President of the Central Liquidity Facility
(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 the agency this week in part cautioning against over-regulation in both areas that might weaken services to members overall.
NASCUS made the points to the agency in a comment letter on the NCUA 2022-2026 draft strategic plan.
Regarding risk from industry consolidation, NASCUS told the agency that a measure of voluntary and strategic consolidation can strengthen the credit union system overall. However, the association said, too much regulation can be a burden that drives some credit unions to seek a merger. Such regulatory burden, NASCUS indicated, can weaken the dual chartering system particularly as federal rules preempt those of the states.
“As state autonomy is curbed by preemption, the credit union system becomes homogenized, eliminating possible alternatives to merger for overburdened credit unions,” NASCUS wrote. “Any regulations that are going to be preemptive must be precisely calibrated to avoid inappropriately hindering effective state supervision. Minimizing preemption of state regulatory and supervisory authority could materially mitigate some of the pressures that drive credit union mergers.”
On climate change, NASCUS urged the agency not to discourage service to entire communities or markets as NCUA works to deal with climate change-related effects on industries and on consumer preferences. In particular, NASCUS wrote, the agency should steer clear of suggestions that services to the agricultural sector should be de-risked.
“NASCUS has concerns that NCUA comments regarding climate change could easily be misconstrued as suggesting credit unions should de-risk agricultural communities and members,” NASCUS wrote.
“Depriving farming communities of local financial services and discouraging agricultural lending is not sound policy and runs contrary to NCUA’s self-stated second strategic goal of improving the financial well-being of individuals and communities through access to affordable and equitable financial products and services,” the association added. “In many cases, agricultural communities have limited access to financial institutions and fewer commercial and consumer credit choices. Encouraging credit unions to de-risk these communities would only further diminish their already limited options. In addition, for some small farms, the prospect of climate change is precisely the reason they need access to commercial credit to facilitate transition to climate-resistant crops.”
In other comments, NASCUS wrote:
- Under goal 1 (ensuring a safe, sound viable credit union system), NCUA should include qualifying language that acknowledges the possibility of reduced risk resulting from growth.
- Under goal 2 (improving financial well-being of members and their communities), supporting financial services for agriculturally based communities is consistent with the goal, and that that strengthening the dual chartering system will spur innovation, strengthen the credit union system, and benefit members. NASCUS also said it welcomed NCUA’s statement that it would streamline its new credit union chartering process. However, NASCUS also said the agency should bifurcate its charter application and share insurance application process to make it easier for prospective credit union founders to understand the state chartering and NCUA share insurance requirements.
- Under goal 3 (maximizing the agency’s performance), the agency should continue working with state regulators “to develop the supervision program of the future and to ensure examiner training is robust and timely.”
LINK:
NASCUS Comments on NCUA 2022-2026 Draft Strategic Plan (Docket No. NCUA-2021-0100)
(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 the rule is properly calibrated for use by low-income credit unions (LICUs), NASCUS told NCUA in a comment letter this week.
The NASCUS comment letter addressed a proposal issued Sept. 23 by the NCUA Board to amend its new subordinated debt rule (which takes effect Jan. 1) to accommodate credit union access to federal investment programs. No other changes to the new rule were offered. The proposed amendment put forward last month, according to NCUA staff, would amend the definition of “grandfathered secondary capital” to include any secondary capital issued to the U.S. government or one of its subdivisions under an application approved before Jan. 1, “irrespective of the date of issuance” (that is, when funds are issued), primarily to benefit low-income credit unions (LICUs).
The letter noted that the proposed amendment is necessary to permit LICUs to participate in the Treasury Department’s Emergency Capital Investment Program (ECIP) without having to reapply for capital treatment rule after the subordinated debt rule takes effect at the start of the new year. The association said it was fine with that change.
However, NASCUS added, the state system also supports additional changes to the subordinated debt rule to “maximize ECIP benefits to LICUs and further reduce regulatory burden.”
NASCUS wrote that it “strongly urged” the agency to “continue evaluating whether the Subordinated Debt rule is properly calibrated to the distinct features of the LICU ecosystem so as not to impede the important work done by these credit unions.”
For example, NASCUS argued, the agency should amend the final subordinated debt rule to allow instruments with 30-year maturities. “While NCUA will now permit LICUs to accept 30-year subordinated debt investment from the ECIP, the agency maintains that LICUs may only recognize 20 years of capital benefit from the funding,” NASCUS wrote. “There is no such fixed 20-year maturity limit in the current secondary capital rule for LICUs, and NCUA would be well within the spirit of the new final subordinated debt rule to allow ‘Grandfathered Secondary Capital’ to maintain the flexibility to set maturity limits based on funding needs and the marketplace.”
In general, the agency’s subordinated debt rule should provide for automatic exceptions to accommodate the terms of subsequent emergency government programs, NASCUS recommended. “Given the lingering effects of the pandemic, it is likely there could be additional Treasury Department funding programs and NCUA should provide certainty that credit unions will have equal opportunity to participate in those,” NASCUS wrote. “A basic sunset provision could provide compatibility between the Subordinated Debt rule and the rules of qualifying government funding program.”
LINK:
(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 confusion, NASCUS wrote in a comment letter to NCUA– one of two posted by the association to the agency this week.
However, the association noted, the regulated and trusted incumbent credit union and banking systems offer the best and safest path forward for the growing consumer use of digital assets and the other innovations brought forth by DeFi.
The letter was in response to the NCUA Board’s July-issued “request for information,” which highlighted the agency’s interest in the impact of distributed ledger technology (DLT, such as blockchain) and DeFi. The original comment due date was extended late last month by 30 days, closing out Oct. 27.
The RFI posed more than two dozen questions over five subject areas: the use of DLT and DeFi applications within the credit union system; development of such projects with third-party relationships or credit union service organizations (CUSOs); risk and compliance management; supervision, including whether and how regulation should be revised to address such activities; and share insurance and resolution – including, among other things, how to distinguish between uninsured digital assets and insured shares.
The state system said it applauded the agency for developing its understanding of DeFi, emerging technologies, and how “credit union stakeholders have engaged with digital assets and emerging DeFi ecosystem.”
However, NASCUS also “strongly recommended” that the agency coordinate with both state and other federal regulators with jurisdiction over products, services and participants engaged in DeFi. “Lack of coordination between regulatory systems can lead to conflicting rules and supervisory expectations that would further complicate and hinder credit union participation in the DeFi ecosystem,” NASCUS stated.
As an example, NASCUS noted that there is a “dizzying array of evolving digital currency with critically distinct features,” pointing to (among others) unregulated decentralized convertible virtual currency (CVC), stablecoins, and central bank digital currencies (CBDCs). “Each of these types of currencies carry different consumer protection, money laundering, and volatility risks,” NASCUS wrote. “Close coordination between regulators will help ensure a common understanding of which products carry which risks.”
Further, NASCUS wrote, NCUA should focus “narrowly on material financial safety and soundness risks with respect to federally insured state credit unions (FISCUs) and defer to state law regarding permissibility of FISCU activities in this space. So doing will ensure the most vibrant innovation for credit union engagement in DeFi by leveraging the power of the dual chartering system.”
In other comments, NASCUS wrote:
- The DeFi ecosystem is diverse, and regulation should distinguish between those credit unions using digital assets, creating digital assets, providing services to members’ use of digital assets, and credit unions’ own use of DeFi technology. “A one-size-fits-all approach to regulating, or supervising, credit union engagement with DeFi will stifle innovation and leave stakeholders at a competitive disadvantage,” NASCUS stated.
- Providing an on-ramp to DeFi stakeholders will require the agency to consider enhanced flexibility in existing rules and powers for credit unions. For example, NASCUS wrote, facilitating credit unions’ ability to explore “banking as a service” (BaaS, offered in partnership with financial technology (fintech) firms) “may require evolving views on associational field of membership or authority to provide pass-thru services to a business member’s customers.” Further engagement with fintechs, NASCUS wrote, “may require expanding permissible services for natural person and corporate CUSOs and permitting credit unions to hold equity investments in non-CUSO fintechs and other entities.” The preemptive application of its rules on FISCUs’ state-authorized powers should be minimized by NCUA, NASCUS argued, to allow the dual chartering system to maximize its potential for innovation among the states.
Comment from National Association of State Credit Union Supervisors
(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 also has key considerations for the agency before it finalizes the rule, NASCUS wrote in its comment letter this week.
More specifically, NASCUS wrote that subordinated debt should be permitted in calculating net worth for CCULR thresholds; that complex credit unions of all sizes can appropriately manage the optionality of both entering and exiting the CCULR; and changes are needed to the current (and proposed) risk-based capital (RBC) and subordinated debt rules in order to avoid a “chilling effect” on the low-income credit union (LICU) secondary capital system.
The NASCUS letter was in response to a call for comments issued by NCUA in July for its proposal to make a simplified measure of capital adequacy available to federally insured credit unions defined as “complex” – meaning those with more than $500 million in assets. According to NCUA, the CCULR framework is comparable to the community bank leverage ratio (CBLR) that went into effect in January 2020 for banks under the 2018 financial regulatory relief law. That rule allows banks to hold a certain, uniform level of capital (now at 9% of assets) as long as they meet certain conditions, including in lending and investments.
Under the NCUA proposed rule, a complex credit union that opts into the CCULR framework and maintains the minimum net worth ratio would be considered well capitalized. For the CCULR, that would begin with 9% as of Jan. 1, 2022, and rise gradually to 10% by Jan. 1, 2024. The credit union would not be required to calculate a risk-based capital ratio under the Oct. 29, 2015, risk-based capital final rule, which also takes effect Jan. 1, 2022. Other qualifying criteria for the proposed framework include: off-balance-sheet exposures equal to 25% or less of total assets; trading assets and trading liabilities that are 5% or less of total assets; and goodwill and other intangible assets that are 2% or less of total assets.
NASCUS wrote developing the CCULR would reduce regulatory burden for those complex credit unions opting-in and would allow them to redirect scarce resources toward other operational priorities, without compromising capital standards or endangering the credit union share insurance fund (SIF).
“By ensuring that the CCULR is available as an option to all complex credit unions, the NCUA can maximize synergy with the RBC rule, maintain flexibility, and achieve greater consistency with sound public policy and the Federal Credit Union Act,” NASCUS wrote. “Thus, the CCULR can achieve its purposes of providing optionality and regulatory relief to complex credit unions by allowing for more effective and efficient deployment capital in service of the members.”
NASCUS also urged the agency to make some additional considerations before finalizing the rule, which – as proposed – would take effect at the beginning of next year, the same date that the RBC rule is scheduled to take effect.
NASCUS recommended that that agency incorporate subordinated debt into the calculation of the CCULR net worth ratio. “Excluding subordinated debt from the CCULR would be an unfortunate step back from nearly a decade’s worth of work to modernize the credit union capital framework,” NASCUS wrote. “Allowing complex credit unions to access capital in addition to retained earnings to meet regulatory benchmarks is sound public policy.”
Further, NASCUS urged the agency provide credit unions with authority to opt in and out of the CCULR with the same flexibility that community banks have udder the CBLR (the proposal allows credit unions to open in at the end of a reporting quarter, and they can only opt out if they provide NCUA with at least 30 days prior notice; banks can do both at any time under their rule). NCUA, in its proposal, said the advance notice was required because credit unions do not have experience, yet, with calculating risk-based capital under the RBC, which takes effect at the beginning of next year.
“While it is true that complex credit unions have not been required to calculate the risk-based capital ratio pursuant to the 2015 final RBC rule, the fact is that the rule has been in place for several years and we believe many complex credit unions have familiarized themselves with the calculations in anticipation of previous, and now pending, effective date(s),” NASCUS asserted.
Finally, the state system urged NCUA to address ongoing concerns about whether the final Subordinated Debt rule is properly calibrated with respect to low-income designated credit unions (LICUs).
“LICUs are a critically important component of the credit union system providing services to predominantly low-income members,” NASCUS wrote. “While an overwhelming majority of LICUs are not subject to the RBC rule, they are subject to the 2020 Subordinated Debt rule. Given the genesis of the Subordinated Debt rule as a corollary to the RBC rule, it is appropriate that refinements to the subordinated debt framework be considered contemporaneously with changes to the RBC rule.”
(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 in its letter to NCUA concerning the latest annual review of the agency’s regulations.
In February, NCUA asked for comments on its annual review of agency rules, which covers one-third of the regulations (the review is conducted over a three-year period to ensure all agency rules are reviewed at least once every three years). Among the rules being reviewed in 2021: Security program, report of suspected crimes, suspicious transactions, catastrophic acts and Bank Secrecy Act compliance (Part 748 of the agency’s rules), among other things.
The state system offered comments in several areas, including BSA/AML compliance, reporting of suspicious transactions, and organization of NCUA rules (particularly those affecting state credit unions).
Regarding anti-money laundering rules, NASCUS noted that Treasury’s Financial Crimes Enforcement Network (FinCEN) is proceeding with a “no-action letter” program for BSA/AML rules over which that agency has enforcement authority. The program will not affect NCUA rules, NASCUS noted. To mitigate confusion, NASCUS recommended that NCUA rules be reorganized to co-locate or otherwise more clearly identify BSA/AML “FinCEN” rules and NCUA specific rules.
NASCUS also urged NCUA to revisit the monthly requirement that credit union boards be informed of suspicious activity reports (SARs) required under BSA/AML. While that may work for federal credit unions (which are required to meet monthly), NASCUS noted, it does not work for state credit unions where boards are only required to meet quarterly. “In other covered industries, including banking, best practice for reporting to the entity’s board is quarterly, or synchronized to regularly scheduled board meetings,” NASCUS wrote. “NCUA should clarify its expectations for how reporting is handled and make clear that for credit unions with less-than-monthly board meeting, reporting SAR filings at the next available board meeting, or quarterly, would satisfy the regulatory requirement.”
In other comments, NASCUS:
- Reiterated the importance of NCUA working with state regulators to develop regulations to implement the Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) National Priorities (National Priorities) as published by the Treasury Department on June 30. NASCUS recommended the agency create a working group with state regulators to develop pending regulations.
- Recommended the agency reinstate the policy of publishing a summary and response to stakeholder comments. “There is real value for stakeholders in understanding NCUA’s response to recommended changes and in gaining insight into the agency’s rational for resisting making various recommended changes,” NASCUS wrote.
- Repeated its call that NCUA reorganize its rules to consolidate and co-locate all National Credit Union Share Insurance Fund (NCUSIF) rules for federally insured credit unions (FISCUs) in one section (or series of consecutive sections), which NASCUS asserted would “provide significant regulatory relief to credit unions without increasing risk to the NCUSIF.”
- Proposed the agency develop a regular review of guidance as a companion to the annual regulatory review. “While not carrying the force of regulation or statute, supervisory guidance provides stakeholders crucial insight into how NCUA interprets compliance with regulation, and as such is just as critical to be regularly evaluated.,” NASCUS wrote.
- Observed that agency rules could be made more consistent by ensuring regulatory provisions containing mandatory elements of compliance contain mandatory language rather than permissive language. “Requirements should also be stated in the active tense such as ‘a credit union shall design its information security program’ rather than passive construction such as a ‘credit union information security program should be designed,’” NASCUS stated.
LINK:
NASCUS comment letter: 2021 NCUA regulatory review
(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 inextricably tied to NCUA’s budget and the overhead transfer rate (OTR), NASCUS wrote in a comment letter this week.
Further, NASCUS wrote, if an elevated NOL is deemed necessary by the agency, NCUA should take steps to reduce the OTR, restoring millions of dollars toward maintaining the NOL and increasing the potential for distributions to stakeholders.
NASCUS was responding to a comment call by NCUA, issued in May, on the agency’s policy guiding determination of the NOL. Now, the NOL (the target equity ratio set for the insurance fund by the NCUA Board) is set at 1.38%. Under the law, the board may set the NOL at anywhere between 1.2% to 1.5%. If the equity level is greater than the NOL, the NCUA Board may vote to make a distribution back to credit unions of the equity in the fund above the NOL (as it did two years ago).
The agency said in May that its re-evaluation of NOL policy was prompted by two events: the current economic landscape (along with the impact of current forbearance programs ending, and likely evictions rising – both perhaps leading to loan underperformance), and pending events related to the corporate asset management estates and end of the NCUA Guaranteed Notes (NGN) Program. Staff noted then that the NOL will no longer have to take into consideration the NGNs after June, since the last of the notes will have been, by then, liquidated (which they were).
The agency sought comments in a variety of different areas, including when public comment should be sought when a change to the NOL is proposed, and the basis for evaluating the insurance fund’s performance.
NASCUS also wrote that it supported continuing the opportunity for stakeholders to participate in considerations of even modest 1 basis point adjustments to the NOL, as well as on the OTR and other adjustments or changes to the NCUSIF.
“Given the cost of maintaining the NCUSIF’s equity ratio at the NOL as determined by the NCUA Board is borne by credit union stakeholders, we believe the policy of notice and public comment before any change of 1 basis point or greater in the NOL should be maintained,” NASCUS wrote.
Writing that the state system supports a “counter-cyclical approach to funding the NCUSIF based on annual modeling utilizing scenarios developed by the Federal Reserve,” NASCUS stated that it supports a moderate recession as the model, with the use of the Federal Reserve baseline and adverse (when available) scenarios to test the model. “NASCUS encourages NCUA to factor into its modeling the historical performance of the NCUSIF and the credit union system to better calibrate the true needs of the SIF while returning as much money to credit unions as prudent for deployment in service of members,” NASCUS wrote.
But discussion of the NOL is not complete, NASCUS asserted, without admitting that the actual equity ratio of the SIF is inextricably tied to NCUA’s budget and the Overhead Transfer Rate (OTR).
“The simple fact is that NCUA has withdrawn over $1.7 billion from the SIF in the past decade ($1 billion of that in just the past five years) to fund agency operations,” NASCUS wrote. “Without question, the NCUSIF should fund its own administration and a robust supervisory program that identifies and mitigates material risk in the federally insured credit union system. But the fact remains that an elevated NOL, combined with the OTR, cannibalizes SIF investment earnings and denies credit unions SIF distribution opportunities.”
The association indicated that the agency should reduce the OTR, which would restore millions of dollars toward maintaining the NOL and increase the potential for distributions to stakeholders.
“Next to setting the OTR, establishing the NOL is one of the most consequential policy determinations administered by the NCUA,” NASCUS wrote. “Over the past several years, NCUA has taken steps to bring more transparency to the OTR and NCUSIF. NASCUS applauds and supports those efforts. We encourage NCUA to continue enhancing the transparency related to the accounting of the NCUSIF, the OTR, and modeling and factors contributing to the determination of the NOL.”
LINK:
NASCUS Comment: Policy for Setting the Normal Operating Level