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NAFCU's Carrie Hunt flagged additional issues and approaches the NCUA should consider as the agency begins its 2019 regulatory review. "NAFCU looks forward to an open dialogue with the agency regarding ways to modernize its existing regulations and find new opportunities to provide more flexibility to credit unions so they are able to grow and better serve their communities," Hunt said.

Hunt, NAFCU's executive vice president of government affairs and general counsel, sent a letter to the NCUA last week to offer comments on each of the agency's regulations under review this year. She also outlined other issues credit unions would like to see prioritized, including:

• fairness in the examination process;
• the current expected credit loss (CECL) standard; and
• regulatory and supervisory expectations regarding cybersecurity.

Hunt expressed the association's appreciation for NCUA Chairman Rodney Hood's recent comments on the agency's efforts to reduce regulatory burden on credit unions.

"NAFCU and its member credit unions greatly appreciate the NCUA Board's openness to closely examining the current and potential effects of the agency's regulations."

Related to the federal credit union charter and field of membership (FOM), Hunt recommended that the federal charter keep pace with changes in state laws, technology and the financial services industry.

"Although legislation is necessary to amend portions of the FCU Act's limitations on chartering, the credit union industry as a whole will benefit from the continued modernization of NCUA's chartering and FOM procedures, as well as removing all non-statutory constraints on FOM chartering and expansion."

Hunt also encouraged the NCUA to support legislation to give the agency more flexibility in setting loan maturity limits, reconsider services credit unions are allowed to provide nonmembers that fall within their FOM, pursue a subordinated debt framework, facilitate strategic investments in corporate credit union service organizations (CUSOs) and more.

To read NAFCU's full recommendations for the regulations under review click here.

Earlier this month, NAFCU President and CEO Dan Berger and other senior leadership met with NCUA Chairman Hood to discuss the regulatory burdens facing the industry and how NAFCU-member credit unions would like to see them addressed. The association's senior leadership also met with the NCUA's Office of Examination and Insurance to discuss credit unions' concerns regarding CECL.