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NAFCU's Carrie Hunt told the NCUA Monday that while it appreciates the aim of transparency, the association is not aware of any problematic trends in voluntary credit union mergers that "warrant such a heavy-handed approach" as that found in the agency's proposal issued this June.

"While a few mergers may present challenging circumstances, whether because of confusion or misinterpretation of NCUA's regulations, there is no compelling need to trade a well-functioning set of rules for a regime that scrutinizes non-material aspects of the merger transaction," Hunt, NAFCU's executive vice president of government affairs and general counsel, wrote in the association's comment letter.

In June, the NCUA Board issued a proposal that would require additional compensation disclosures and more member-to-member communications for federal credit unions undergoing voluntary merger.

Hunt said the goals of the NCUA proposal, such as more expansive disclosures of merger-related financial arrangements and more advance notice to credit union members ahead of a merger vote, could be carried out through existing authorities. "Given NCUA's ability to apply special requirements in voluntary mergers, NAFCU does not see how the proposed rule constitutes anything less than regulatory burden," she wrote.

She added that credit unions have benefited from the NCUA's current merger regulations as they provide flexibility, whereas this proposed process "may offset the economic benefits that accrue from careful planning and timely execution of the merger transaction."