August NCUA Report; Reg Review Comment Letter
Written by Steve Van Beek
NCUA recently released the August NCUA Report newsletter. Â This newsletter can provide a good summary of NCUA's recent actions as well as clues about future NCUA actions. Â
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. Â For example, Boardmember Fryzel discusses NCUA's Regulatory Review process and how it covers NCUA's Bank Secrecy Act regulation - Part 748. Â However, the 439-page FFIEC BSA Manual is not part of NCUA's Regulatory Review. Â
Another example - the recent online authentication guidance. Â Letter to CUs here. Â Enclosure here.
IâÂÂm 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. Â
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NAFCU has submitted our comment letter on NCUA's Regulatory Review. Â Â