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NAFCU Senior Counsel for Research and Policy Andrew Morris wrote to the NCUA to offer general support for its proposed rulemaking related to Office of National Examinations and Supervision (ONES) asset threshold determination. The proposal, unanimously approved at the NCUA Board’s February meeting, would adjust the threshold used for determining whether a credit union will be supervised by ONES from $10 billion in assets to $15 billion.

In addition, to lessen any disruption, the proposal notes the credit unions already subject to ONES supervision are “grandfathered” and remain subject to such supervision even if they are below the proposed $15 billion threshold.

"NAFCU supports efforts to conserve the NCUA’s existing supervisory resources by tailoring the threshold for specialized supervision by [ONES] according to risk-based criteria," wrote Morris. "Increasing the asset threshold used for determining whether a covered credit union will be supervised by ONES is appropriate given the industry’s extraordinary, pandemic-related asset growth over the past two years and low levels of fundamental risk."

Morris recommended the NCUA increase the proposed Tier 1 threshold from $15 billion, as proposed, to $20 billion to better reflect growth of insured shares. In addition, Morris requested the NCUA "explicitly exclude non-grandfathered Tier I credit unions from the proposed definition of 'ONES credit union' for the sake of clarity."

Morris also encouraged the NCUA to ensure that appropriate coordination exists between the agency's regional offices and the CFPB to prevent instances of examination overlap or confusion resulting from the application of differing standards and expectations.

NAFCU in February sent members a Regulatory Alert to break down the proposal and solicit feedback; the association will continue to engage with the NCUA to ensure credit union concerns are heard.