Update:Help NACUSO Fight Against the Regulation of CUSOs -Comment Letter Included

NACUSO Members Call to Action 2nd Letter

NCUA has made it very clear. They are headed down the path toward the direct regulation of CUSOs. The proposed Amendment to the CUSO Regulation, which has now been published in the Federal Register, is the first step. NACUSO has issued its Comment Letter to the NCUA on the proposed CUSO regulations, which is available for your review, as well as the NCUA Proposed CUSO Regulation Reference Points for your consideration and reference in submitting your own comment letter to NCUA (see links below). We still need three things from our members.

  1. We need our members to draft and submit a comment letter to NCUA in your own words expressing your opinion on the Proposed CUSO Regulation.
  2. We need our members to motivate other CUSO and credit union leaders and volunteers to send their own comment letter. We especially want comments from credit unions. So contact everyone in your professional network and be an active advocate to get these letters out. Be a nuisance if necessary. This is no time to sit on the sidelines.
  3. We need information from credit unions on the value that CUSOs bring to their credit unions. Please send this information to NACUSO so we can compile it and forward it to NCUA.
    1. What CUSOs does your credit union own and/or use?
    2. How has your credit union benefited from CUSOs?
    3. Have CUSOs provided valuable services to the members or the credit union that were not available or affordable without CUSOs?
    4. Have CUSOs increased the operational expertise available to the credit union?
    5. Please provide your estimate of the financial impact that CUSOs have made on your credit union in income and cost savings?
    6. What would be the impact upon your credit union if CUSOs could no longer provide the services to your credit union?

NCUA says they see CUSOs as risky but the true risk is too few CUSOs not too many CUSOs. What other tool is available to credit unions to obtain the cost saving benefits of scale and alternative revenue sources that will earn sufficient net income to stay in business?   Help us help you, educate NCUA.

In addition to using it in our own advocacy efforts at NACUSO on your behalf, we intend to also share this information with CUNA, NAFCU and various State Leagues and request their assistance in our advocacy efforts. Please contact your state League, and please feel free to contact CUNA and/or NAFCU as well, to help ensure an industry wide support of our position that CUSOs are too valuable to the industry and the NCUA has not made a compelling case to support their added regulation of CUSOs.

Please provide your response on or before August 15 to enable us to timely assimilate the information. We will be happy to share the results with you so that you will have the information to be a CUSO advocate.

If we do not take a strong stand now and push back on regulatory overreach now, we will live to regret it. Just as in CUSOs, together we are stronger than any one of us.

Thank you for your support.


Jack M. Antonini

Jack M. Antonini
President & CEO

Click here to view NACUSO’s Comment Letter to the NCUA

Click here to view actual NCUA proposal. The link is to the NCUA Board Agenda – Items 2a and 2b are the CUSO rule. Click on 2b for the full proposed rule, and the CUSO regulation is covered on pages 1-15.

Click here to view “CUSO Regulation Reference Points” to consider in your comment letter to the NCUA.