Regulatory Review: Regulatory Publication and Voluntary Review as Contemplated by the Economic Growth and Regulatory Paperwork Reduction Act

The Defense Credit Union Council (DCUC), representing over 200 defense-affiliated credit unions, supports the NCUA's voluntary regulatory review and modernization efforts. They advocate for specific updates, including increasing loan approval thresholds, clarifying reimbursable expenses for officials, and providing greater flexibility for corporate credit unions and payday alternative loans.

America’s Credit Unions, an advocacy organization representing credit unions, supports the NCUA's voluntary participation in the EGRPRA review and its efforts to reduce regulatory burdens. They provide specific recommendations to modernize and simplify various regulations, including requests for greater flexibility in asset management, the removal of mandatory succession planning in favor of guidance, and the reclassification of certain guidance documents as nonbinding.

The National Association of State Credit Union Supervisors (NASCUS) supports the NCUA's voluntary regulatory review under the EGRPRA and provides specific recommendations to reduce regulatory burdens. They advocate for consolidating regulations for state-chartered credit unions, modernizing corporate credit union rules, and streamlining the appeals process for material supervisory determinations.

The United Nations Federal Credit Union (UNFCU) supports the NCUA's Decennial Review and urges the Board to modernize documentation requirements for trade confirmations and expand the scope of permissible investments to include asset-backed securities. They argue these changes will improve operational efficiency and provide credit unions with greater flexibility to manage risk through diversification.

The Endangered Small Credit Union Defense (ESCUD), a nonprofit advocacy organization, supports the NCUA's voluntary EGRPRA review as a tool for deregulation. They urge the Board to use this process to implement bold, asset-tiered regulatory relief specifically for small credit unions to reduce examination burdens and costs.

The Endangered Small Credit Union Defense (ESCUD) supports the NCUA's voluntary EGRPRA review process as a tool for deregulation. They urge the Board to use this review to implement asset-tiered relief, specifically recommending reduced examination frequencies and simplified compliance requirements for small, low-risk credit unions.

QuantyPhi, a shared-services provider for credit unions, supports the NCUA's voluntary EGRPRA review aimed at reducing regulatory burdens for small institutions. They specifically advocate for the NCUA to explicitly recognize simplified, Call Report-based asset-liability management (ALM) modeling as a permissible compliance option for less complex credit unions to improve supervisory efficiency and reduce operational costs.

Iran Ortiz Pizarro, a private citizen, supports the NCUA's move toward principles-based rules but suggests specific improvements to the regulatory review. The commenter argues for simplifying reporting processes for smaller credit unions and coordinating with other agencies to reduce redundant paperwork during cyber incidents.