Compliance Blog

Written by Steve Van Beek

Last week, NCUA issued their listing of their annual review.  The listing includes Parts 700 through 710 of NCUA's regulations - including all the subparts of Part 701.

In the press release, NCUA Chairman Debbie Matz indicated NCUA would focus on reducing the regulatory burden on credit unions:

"Each year we take a fresh look at a different one-third of NCUA regulations to ensure that our standards are up to date,” said NCUA Board Chairman Debbie Matz. “This year, in the spirit of President Obama’s Executive Order 13579 on Regulations and Independent Regulatory Agencies, we are particularly seeking comments on rules that may be ‘outmoded, ineffective, insufficient, or excessively burdensome.’ We are committed to ‘modify, streamline, expand, or repeal’ rules that are not required by statute and would not jeopardize safety and soundness.”    

Comments.  NCUA will be taking comments until August 3, 2012.  NAFCU's Regulatory Affairs team will be preparing a Regulatory Alert and soliciting comments from NAFCU member credit unions.  Keep an eye out for the alert and consider sharing your comments on which areas could be updated (or removed) to ease the regulatory burden.  A "top three" wish list might be a good way to handle this issue.      

Below are links to the regulations being reviewed by NCUA:

• Part 700 - Definitions
• Part 701 - Organization and Operation of Federal Credit Unions [Parts 701.1 through 701.39]
• Appendix A to Part 701 - Model Federal Credit Union Bylaws
• Appendix B to Part 701 - Chartering and Field of Membership Manual
• Part 702 - Prompt Corrective Action
• Part 703 - Investment and Deposit Activities
• Part 704 - Corporate Credit Unions
• Part 705 - Community Development Revolving Loan Fund Access for Credit Unions
• Part 706 - Unfair or Deceptive Acts or Practices
• Part 707 - Truth in Savings
• Part 708a - Bank Conversions and Mergers
• Part 708b - Mergers of Federally-Insured Credit Unions; Voluntary Termination or Conversion of Insured Status
• Part 709 - Involuntary Liquidation of Federal Credit Unions and Adjudication of Creditor Claims Involving Federally Insured Credit Unions in Liquidation
• Part 710 - Voluntary Liquidation 

Obviously, each regulation listed above has a different impact on credit unions and, specifically, on compliance officers.  Over the next couple of months, it might be a good idea to keep track of areas that are "excessively burdensome" and provide comments to NCUA on ways they could make the lives of credit union compliance officers easier.  

***

CFPB Streamlining.  Today is NAFCU's internal deadline for submitting your comments on the CFPB's efforts to streamline the consumer regulations it inherited.  NAFCU Regulatory Alert 11-EA-32 contains the details.  If you haven't gotten your comments to NAFCU on which actions the CFPB should take to streamline their new regulations - now is your chance.  If you have comments, send them to Dillon Shea - dshea@nafcu.org - and we'll pass your concerns along to the CFPB in NAFCU's comment letter.  Comments are due to the CFPB by March 5, 2012.