At their December Board Meeting, the NCUA proposed a modernization to their regulations covering Loan Participations, Eligible Obligations and Notes of Liquidating Credit Unions. We see this as a significant improvement in helping credit unions to not only better serve their members, but to enable them to compete in the highly competitive environment we are operating in with so much fintech innovation. Fintech innovators have made it easy for consumers to obtain financing right through their phones that previously would have been provided to members by their credit unions. In order to compete, the industry has been working with some of the fintech innovators, but it has been cumbersome and challenging. The proposed amendments to Part 701.21, 701.22 and 701.23 will allow credit unions to remain innovative and give credit unions the ability to adapt to continuously changing lending markets.
We wanted to share our comment letter in support of the proposed changes in NCUA’s regulations, in hopes you will take the time to pro-actively support these changes in the regulations. You can read NACUSO’s comment letter to the NCUA Board here.
We have also provided a simplified and shorter sample comment letter (see attached) that you can use if you’d like a template to help you with writing a comment letter in support of these positive changes in the NCUA’s lending regulations. We encourage you to personalize your comment letter on your letterhead and include examples of how this will help your credit union or CUSO in your mission of providing member loans and service. Ideally a comment letter that simply indicates you support the proposed rule changes is all that is required by the NCUA. Comment letters are due to the NCUA by February 28, 2023. You can submit electronically here.
Should you have any questions, please do not hesitate to contact us at NACUSO.
Jack M Antonini
President & CEO – NACUSO
