Leagues Comment on NCUA Proposals

National Credit Union Administration

This week, the California and Nevada Credit Union Leagues provided comments to the National Credit Union Administration (NCUA) on three proposed rules:

1. Voluntary Mergers of Federally Insured Credit Unions
The Leagues fully support complete, accurate, and transparent disclosure to members regarding a proposed merger. However, we do not believe the NCUA needs to rewrite the merger rules to achieve this. In our letter we call on the NCUA to revoke the proposed rule or make significant improvements, particularly in the areas of covered persons, member-to-member communication, and timing requirements.

2. Supervisory Review Committee; Proposed Procedures for Appealing Material Supervisory Determinations
The Leagues generally support the Board’s proposed improvements and offer recommendations. One recommendation of particular interest, from the Leagues’ Regulatory Advocacy Committee, is that the Board include credit union executives in the Supervisory Review Committee (SRC) pool and for each appeal. “Having a credit union executive on the SRC will increase the perception of a truly independent review since the SRC would not be solely made up of NCUA staff. Credit unions may be more likely to appeal a Material Supervisory Determination when it will be ‘a jury of their peers.’”

3. Appeals Procedures
The NCUA proposes to replace all the appeal procedures scattered throughout the regulations into one consolidated rule. This will make it easier for credit unions to find and understand—and hopefully use the appeals process more often. The Leagues support the rule, and make recommendations for improvement. Again from our Regulatory Advocacy Committee, we recommend not limiting credit union representation at oral hearings to only two individuals.

For more information, please contact the League's Vice President of Regulatory Advocacy Sharon Lindeman at 909-212-6063, or sharonl@ccul.org