NWCUA Regulatory Advocacy Update: Response to NCUA’s Proposed Rules
The weekly Regulatory Advocacy Update outlines the NWCUA’s efforts to reduce the regulatory burden on credit unions and protect the larger movement. Included here are update letters on two comment letters written by the NWCUA regarding the NCUA’s proposed rules on emergency liquidity and troubled condition.
October 2, 2012
The Association submitted two comment letters this past week in response to rules proposed by the Natoinal Credit Union Administration (NCUA) on Emergency Liquidity and Troubled Condition.
Rivermark’s Sharon Pasero organized a group of compliance officers from Oregon and Washington to make sure the Association’s position on Emergency Liquidity accurately reflected the views of NW credit unions. The Association made five suggestions:
- Liquidity policy statements as adequate for credit unions of all asset sizes;
- Adjusting the asset sizes that fall under the three tiers;
- Adding the FHLB as an emergency liquidity option;
- Adjusting the formula for subscribing to the CLF;
- Providing technical assistance to help reduce the cost of compliance for small and mid-sized credit unions
The Regulatory Affairs Committee met on Oct. 1 to put the final touches on the Association’s comment letter on the NCUA’s proposed rule on Troubled Condition. There was some discussion about whether to suggest the NCUA issue an alternative to the current proposal, requesting that an independent third party make the final CAMEL determination if state and federal regulators were not able to come to a consensus. The committee concluded that this took away from the main point that this was an egregious overstep by federal regulators pre-empting state rights.
“I am excited by the level of interest and participation by credit union executives and staff in helping develop regulatory positions,” NWCA Director of Regulatory Advocacy John Trull said. “Credit union leadership on regulatory issues will result in less burdensome regulation.”
The NWCUA Regulatory Advocacy team works with state and federal regulators to help reduce the regulatory burden on credit unions and protect the credit union movement. The Association encourages members to participate in the regulatory process. If you have any questions on these or any regulatory issues, please contact Director of Regulatory Advocacy John Trull at email@example.com, or at 503.350.2209.