From: CU Insight
The Credit Union National Association (CUNA) submitted comments to the National Credit Union Administration (NCUA) regarding the Office of General Counsel’s list of regulations scheduled for review this year. Additionally, CUNA pushed for reducing the creeping complexity of credit union regulatory burden by: 1) urging NCUA to go beyond clarifications and reduce regulatory requirements substantially to provide meaningful regulatory relief for credit unions; and 2) urging NCUA to add new or expand existing rules only if required to do so by law, or doing so is clearly warranted based on a compelling safety and soundness reason that can be satisfactorily addressed in no other manner.
See full letter below:
August 4, 2014
Office of the General Counsel
National Credit Union Administration
1775 Duke Street
Alexandria, VA 22314
Re: 2014 Regulatory Review
To Whom It May Concern:
The Credit Union National Association (CUNA) appreciates the opportunity to submit comments regarding the Office of General Counsel’s list of regulations scheduled for review this year. By way of background, CUNA is the country’s largest credit union advocacy organization, representing our nation’s state and federal credit unions, which serve over 99 million members.
We appreciate NCUA’s willingness to accept public input on the regulations that are scheduled for review this year. We support the agency’s policy of continually reviewing its regulations to determine whether they should be updated, clarified, simplified, or eliminated. Each year, NCUA examines one-third of its regulations as part of this annual review process.
As NCUA is aware, the cumulative regulatory burden on credit unions is at an all-time high, due not only to NCUA’s activities but also resulting from the activities of other agencies, including new regulations pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act.
In light of the imperative need to reduce credit unions’ regulatory obligations, we urge NCUA to add new or expand existing rules only if required to do so by law, or doing so is clearly warranted based on a compelling safety and soundness reason that can be satisfactorily addressed in no other manner.
We also encourage the agency to consider what is categorized as regulatory relief. NCUA and other agencies often label updates and clarifications as regulatory relief. However, to a credit union, real regulatory relief is only achieved when less time and money are required to fulfill regulatory requirements. We urge NCUA to go beyond clarifications and reduce regulatory requirements substantially to provide meaningful regulatory relief for credit unions.
CUNA will be sending the agency more ideas and recommendations for credit union regulatory reductions in the coming weeks. In the meantime, our comments in this letter focus on Part 748, Security Program, Report of Suspected Crimes, Suspicious Transactions, Catastrophic Acts, and Bank Secrecy Act Compliance, as well as the process for identifying rules for review and soliciting comments. We will also provide input on NCUA’s Economic Growth and Regulatory Paperwork Reduction Act request for comments by the September 2 deadline.
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