Compliance Blog

Aug 09, 2011

August NCUA Report; Reg Review Comment Letter

Written by Steve Van Beek

NCUA recently released the August NCUA Report newsletter.  This newsletter can provide a good summary of NCUA's recent actions as well as clues about future NCUA actions.  

Boardmembers Gigi Hyland and Michael Fryzel (Page 4) both discuss regulatory burden - and both do so without mentioning the increasing amount of guidance being issued by NCUA and other regulators.  For example, Boardmember Fryzel discusses NCUA's Regulatory Review process and how it covers NCUA's Bank Secrecy Act regulation - Part 748.  However, the 439-page FFIEC BSA Manual is not part of NCUA's Regulatory Review.  

Another example - the recent online authentication guidance.  Letter to CUs here.  Enclosure here.

I’m of the opinion that any discussion of regulatory burden should address the increased use of guidance documents by regulators in lieu of proposing regulations through the notice-and-comment rulemaking process.  

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NAFCU has submitted our comment letter on NCUA's Regulatory Review.  Â