Comment from Iran, Ortiz Pizarro

I’m submitting this comment regarding the NCUA’s current regulatory review. As a private citizen, I’ve reviewed the proposal to identify rules that might be outdated or just plain unnecessary, with a particular focus on the "Corporate Credit Unions" and "Safety and Soundness" categories. I generally support the NCUA’s move toward "principles-based" rules because they are more flexible. However, I believe the Board should simplify the reporting process for smaller credit unions and rethink how much of a headache the new 72-hour cyber incident reporting rule might be for staff during an actual crisis. The 2023 rule requiring a 72-hour notification for cyber incidents makes sense for keeping the system safe. But when a credit union is actually dealing with a hack, having to report to multiple different agencies at the same time is a huge burden. Following Question 5 of the review, I suggest the NCUA coordinate with other federal agencies so that credit unions aren't stuck doing double the paperwork while they’re trying to fix a security breach. "Small entities," those with less than $100 million in assets, don't have the same massive budgets or teams as big banks. For these smaller groups, every new rule means a ton of extra time and money spent just on compliance. To answer Question 14, I recommend that the NCUA offer more "Safe Harbors" for small credit unions that already have high safety ratings, so they don’t have to spend so much time on repetitive reporting. The 2021 update to the derivatives rule was a great move because it gave Federal Credit Unions more freedom to manage their own risks. The Board should keep using this "principles-based" approach for all safety and soundness rules. It allows credit unions to adapt to new technology and economic changes without the government having to rewrite the entire rulebook every few years. Taking the time to review these rules every ten years is a great way to keep the credit union system healthy. By making reporting easier for small institutions and reducing redundant paperwork, the NCUA can help credit unions stay efficient while still keeping everyone’s money safe. Respectfully, Iran Ortiz Pizarro Private Citizen