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UPDATE (04/01): The NCUA has approved a 60-day extension for this comment period. NAFCU will notify credit unions of the new deadlines to comment through the Regulatory Alert and directly to the NCUA. 

Following the NCUA's proposal to amend the agency's corporate credit union rules, NAFCU is seeking member credit union feedback on how the changes would impact operations. Credit unions can submit comments through NAFCU's Regulatory Alert.

In the Regulatory Alert, NAFCU highlights that the proposal would:

• permit a corporate credit union to make a noncontrolling, de minimis investment in a natural person credit union service organization (NP CUSO) without the CUSO being classified as a corporate CUSO, which is generally subject to additional restrictions and reporting obligations;
• expand the categories of senior staff positions at member credit unions eligible to serve on a corporate credit union's board;
• remove prescriptive requirements for a corporate credit union's enterprise risk management expert; and
• clarify that corporate credit unions may purchase subordinated debt instruments of natural person credit unions under a corporate credit union’s lending authority. However, a corporate credit union must fully deduct the amount of the subordinated debt instrument from its tier-1 capital.

NAFCU further details how these changes would potentially impact credit unions and would like feedback on whether:

• the proposal would have a positive impact on the availability of CUSO funding; and
• the more expansive definition of CUSO would impact corporate credit unions' reporting obligations or investment limitations.

Read more about the proposal and submit comments via NAFCU's Regulatory Alert.

In addition, the NCUA Monday announced that it has extended the comment period on its proposed rule for combination transactions by 60 days. NAFCU submitted comments to the agency prior to the extension and recommended an expeditious timeline for approval and suggested a careful review of its existing requirements for merger transactions to streamline the process. The association may consider submitting supplemental comments during the extended comment period.