NACUSO, while supportive and appreciative of NCUA’s proposed amendments to the Member Business Lending rules, NACUSO provided suggestions in its comment letter to the NCUA (view letter: NACUSO MBL Comment Letter to NCUA dated 8-13-2015)… Read more
Posts By: Shawna
NACUSO has long expressed its concern about the growth of NCUA and its extension of its regulatory arm, both directly and indirectly, into areas of questionable statutory authority such as the de facto regulation and examination of CUSOs through the 2013 CUSO rule that is beginning to be implemented by NCUA this year. The extension of regulatory authority by NCUA comes with increased costs, costs that are paid for ultimately by credit union members. NCUA not only wants expanded regulatory authority over CUSOs, it also is seeking regulatory authority over all vendors that sell products and services to credit unions.
NCUA takes money from the insurance fund to pay for its operations through the Overhead Transfer Rate (“OTR”). The OTR currently funds 71.9% of NCUA’s budget. NCUA does not have to justify its expenses or ask permission from anyone to take as much money as it deems appropriate from the share insurance fund for its operations. … Read more
As we explained when we announced the formation of the NACUSO Advocacy Fund a few months ago, the regulatory climate that enabled credit unions to maximize the benefits of CUSOs and collaboration is under siege, and as an industry, we need to respond. NACUSO has established an Advocacy Fund to supplement its efforts to promote and protect a collaboration/CUSO friendly regulatory climate.
As was announced at the NACUSO Annual Conference, we have developed a NACUSO 2015-16 Legislative & Regulatory Advocacy Plan, based upon the four basic precepts upon which our advocacy work is based. Those four pillars are designed to support an environment that:… Read more
NACUSO has filed its official Comment Letter with the NCUA addressing their revised Risk-Based Capital (“RBC”) regulation, and we are providing it to you so you will be aware of our position on this very important issue. We have also included a “sample” comment letter that you can use as a template for your own comment letter to the NCUA regarding the revised RBC proposal.
While we acknowledge and appreciate the improvements in some risk weights from the original RBC proposal, including reducing the risk weighting on wholly owned CUSOs to 100%, we remain concerned with a 150% risk weighting on CUSOs that are owned by multiple credit unions. The CUSOs that are owned by more than one credit union are providing much needed economies of scale, helping to obtain levels of expertise that an individual credit union may not be able to afford or obtain on their own, while helping to share/spread risk and lower costs. … Read more