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NAFCU President and CEO Dan Berger Wednesday wrote to the NCUA calling for the removal of a requirement for credit unions to seek guidance from the NCUA prior to holding virtual meetings during disasters and states of emergency. Over the course of the pandemic, credit unions have successfully maintained operations and served the needs of their members, with the guidance and flexibility granted by the NCUA. 

The association also urges the NCUA to issue a Letter to Credit Unions extending the emergency exception to in-person meeting requirements for the rest of 2022. 

“We hope that you will work with us to recognize the evolving nature of disasters in our society and the ability of ubiquitous technology to mitigate the impacts of these disasters,” stated Berger.

In March of 2020, Berger wrote several letters to the NCUA calling for guidance surrounding various regulatory compliance concerns at the outset of the pandemic crisis, including broader flexibility around virtual meetings. 

The NCUA later released a Letter to Credit Unions stating that federal credit unions could “adopt a bylaw amendment to hold annual meetings of the members and special member meetings for authorized purposes other than member expulsion, virtually, in certain circumstances.”

In NCUA’s Letter, one of the circumstances required for the emergency virtual meeting exception was issued guidance from the NCUA notifying the credit union that it was appropriate to invoke this bylaw. This onerous requirement for credit unions to receive permission to hold meetings virtually during times of disasters, risks the NCUA “becoming overburdened with evaluating and responding to multiple requests in many regions of the country at the same time,” noted Berger. 

Despite worldwide focus on the virus, it has become apparent that the scope and frequency of natural disasters are increasing, resulting in greater risks to the nation’s aging infrastructure. 

“In rural communities, where credit unions frequently represent the sole financial services provider, these impacts are often deeply felt, as the few roads in the area may represent the only means of movement,” wrote Berger, “Ultimately, the requirement for in-person attendance at credit union meetings only serves to place barriers in the way of those who might wish to get involved in their credit union but are unable to for any of the aforementioned reasons.”

Of note, Berger also mentions the lengths credit unions have gone to in engaging innovative technological platforms to not only conduct virtual meetings but to meet the needs of their members during this tumultuous time. “NAFCU does not view technology as a complete solution to issues of accessibility, but the COVID-19 pandemic has demonstrated the efficacy of virtual meeting systems and in disaster scenarios technology often represents the safest, best option,” stated Berger. 

“NAFCU urges the NCUA to provide credit unions permanent flexibility in determining how they hold their members meetings,” concluded Berger. 

NAFCU remains engaged with NCUA on this and other issues to ensure credit unions are not faced with overly burdensome regulatory compliance requirements. Read Berger’s full letter here.