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As the NCUA seeks feedback on its existing overhead transfer rate (OTR) methodology and proposed clarifications related to how the methodology is applied to apportion operating fees charged to federal credit unions, NAFCU is gathering credit unions' comments to inform its recommendations to the board.

The NCUA at its July meeting issued the request for comment (RFC), which NAFCU – in a new Regulatory Alert – highlights:

• seeks views about how or whether the NCUA should modify the current three-tier operating fee schedule, and how or whether the board should increase the asset threshold below which federal credit unions are assessed no operating fee;
• proposes changes to how the operating fee is calculated, including reimbursing a portion of capital project budgets through the OTR and reassigning miscellaneous revenues to the OTR-covered portion of the annual budget; and
• asks what incentives the board might provide to encourage credit unions to participate in the annual voluntary diversity self-assessment.

The association's Regulatory Alerts seeks feedback on whether the threshold below which a federal credit union pays no operating fee should be increased and what changes the NCUA should consider related to the operating fee schedule.

NAFCU has previously questioned the agency’s principles-based OTR methodology adopted in 2017 and will continue to work with the agency to ensure a fair, common-sense OTR methodology.

Get detailed background information and insights on the OTR and operating fee in NAFCU's Regulatory Alert. Comments are due to NAFCU Oct. 1 and can be submitted through the alert; comments are due to the NCUA 60 days after publication in the Federal Register.