NWCUA Regulatory Advocacy Update: Northwest Credit Unions Respond to NCUA’s Proposed Rules

The National Credit Union Administration (NCUA) proposed four rules at its September board meeting, all of which are considered generally positive for credit unions, and Northwest credit union advocates responded with suggestions and concerns related to the definitions of small and rural credit unions.

The first rule proposed by the NCUA in September encourages more federal credit unions to offer Payday Alternative Loans (PAL), while the second would add Treasury Inflation Protected Securities (TIPS) to the permissible investments list.

The other two rules garnered responses from credit unions in Oregon and Washington, as the third rule proposed by the NCUA would change the official definition of a small credit union from $10 million in assets to $30 million. The fourth rule will allow rural charters to have a field of membership equal to 3 percent of the state population.

While the NWCUA generally supports increasing the asset-based definition of a small credit union, a letter to the NCUA from Spokane Media Federal Credit Union President and CEO Debie Keesee, who also serves as the chair of the Northwest Credit Union Association (NWCUA) board of directors, not only identified the small credit union definition as a rule that did not adequately raise the asset threshold for small credit unions, but also recognized the initial comment period was only 30 days long.

Keesee worked with both the Credit Union National Association (CUNA) and the NWCUA to extend the comment period deadline. Following the extension, she worked with NWCUA staff on a comment letter that incorporated the survey responses from a number of other credit unions around the state. Keesee made an argument for credit unions with $100 million in assets to be defined as a small credit union, but recognizes that the NCUA is more likely to consider expanding the definition to somewhere between $40 and $50 million. BECU’s Parker Cann also wrote a letter to the agency supporting Keesee’s position.

“Debie made a strong argument, and I believe that there is a good chance the NCUA will raise the threshold for small credit union to something above $30 million,” said John Trull, the Association’s director of regulatory advocacy. “If that happens, Debie Keesee would be largely responsible.”

Kathie Philp, CEO of Pacific Crest Federal Credit Union, worked with NWCUA staff on a letter to the NCUA regarding the proposed changes to a rural charter. Philp recognized that the proposed change only affected credit unions in the 13 most populous states. She encouraged the NCUA to eliminate the current numerical cap that makes a rural charter too restrictive, pointing out that the USDA Frontier and Remote Area Codes (FAR) would serve as a widely accepted rural definition that would make the rural community charter more attractive. FAR level one defines rural as being an area located more than one hour away from a population center of at least 50,000 people.

Both comment letters are available in the Association’s Regulatory Advocacy Comment Letter Archives.


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 jtrull@nwcua.org, or at 503.350.2209.

Posted in Advocacy News, Industry Insight, NCUA, NWCUA, Strategic Link.