DCUC Supports NCUA Deregulatory Proposals in Four Comment Letters

Jason Stverak

​Defense Credit Union Council (DCUC) has submitted four comment letters to the National Credit Union Administration (NCUA) in response to the agency’s second round of proposed regulatory changes under its ongoing Deregulation Project. DCUC expressed support for all four proposed rulemakings, noting the importance of modernizing and streamlining regulations for federally insured credit unions.
 
In its letter regarding the proposed removal of segregated deposit and collateral requirements when a federally insured credit union acts as a surety or guarantor, DCUC endorsed the NCUA’s principles-based supervisory approach. DCUC voiced that aligning these requirements with the agency’s commercial lending framework adopted in 2016 would reduce unnecessary complexity and better reflect the operational realities of credit unions.
 
DCUC also supported the NCUA’s proposal to eliminate § 701.25b, which currently imposes separate approval and documentation requirements for loans made to other credit unions. DCUC stated that these additional requirements are duplicative and unnecessary, and affirmed that credit union boards are best positioned to determine appropriate approval policies within the framework of existing regulatory limits.
 
Regarding the proposed amendments to the Accuracy of Advertising and Notice of Insured Status rule, DCUC supported eliminating the standalone requirement that credit unions include a statement in advertisements that they are insured by the NCUA. DCUC explained that share insurance coverage is more effectively communicated through existing required disclosures at branches, principal places of business, and on credit union websites.
 
In its fourth letter, DCUC supported the NCUA’s proposal to amend catastrophic act reporting requirements by requiring notification to the “NCUA” rather than a specific regional director and extending the reporting timeframe from five business days to 15 calendar days. DCUC encouraged the agency to reinforce through guidance, outreach, and examiner communication the importance of notifying the agency as soon as possible within that timeframe. DCUC also expressed support for the optional use of online notification tools, such as the NCUA’s existing cybersecurity incident reporting form.
 
Across all four letters, DCUC commended the NCUA’s efforts to streamline and modernize its regulations and encouraged continued collaboration and engagement with the credit union industry throughout the Deregulation Project.
 
“DCUC strongly supports the NCUA’s efforts to modernize and streamline regulations in a way that reduces unnecessary burden while maintaining safety and soundness,” said Jason Stverak, DCUC Chief Advocacy Officer. “These proposed changes reflect a thoughtful, principles-based approach that recognizes credit unions are well-positioned to manage risk responsibly. We appreciate the agency’s continued engagement with the industry and look forward to working collaboratively throughout the Deregulation Project.”

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