Requirements for Insurance

The National Association of State Credit Union Supervisors (NASCUS) opposes the proposed rule because it eliminates codified cross-references that help state-chartered credit unions identify applicable federal regulations. They argue that removing these references increases the regulatory burden and complexity for these institutions, suggesting that the NCUA should instead consolidate all applicable rules into a single section.

The Cooperative Credit Union Association, Inc., representing nearly 200 credit unions, supports the proposed rule to remove cross-references in Part 741 of NCUA Rules and Regulations. They also request that the NCUA provide a plain-language guidance index with weblinks on its website to help credit unions navigate their federal compliance responsibilities.

America’s Credit Unions supports the proposed rule to simplify and consolidate the regulatory code for federally insured credit unions. They argue that removing duplicative cross-references and clarifying the specific applicability of certain provisions to federal versus state-charted credit unions will reduce compliance burdens and improve regulatory clarity.

The Wisconsin Credit Union League is writing on behalf of Wisconsin's credit unions to support the NCUA's proposed rule. They argue that the proposal simplifies and streamlines regulatory text by removing redundant provisions without changing the underlying compliance obligations.

The Illinois Credit Union League supports the NCUA's proposal to streamline and simplify regulations by removing duplicative provisions and cross-references. However, they request that the NCUA create an external reference list to help smaller credit unions identify applicable regulations and provide clear guidance within other parts of the regulations to avoid confusion.

The Cooperative Credit Union Association, Inc., representing nearly 200 credit unions, supports the NCUA's proposal to increase the "Major Assets" prohibition thresholds from $2.5 billion and $1.5 billion to $10 billion. They argue that this change will provide credit unions with greater flexibility to recruit and retain experienced management officials from the banking sector to improve corporate governance and risk management.

The Defense Credit Union Council (DCUC) opposes the proposed rule because it eliminates helpful cross-references that serve as a practical compliance aid for credit unions. They argue that the change does not meaningfully reduce regulatory burden and instead removes useful context for understanding applicable regulations.

ORNL Federal Credit Union supports the NCUA's proposed rule to simplify regulations by removing duplicative cross-references without changing substantive compliance obligations. The credit union suggests that the NCUA provide a non-binding, plain-language reference guide to maintain navigational clarity for institutions.

The Endangered Small Credit Union Defense (ESCUD), a nonprofit advocacy organization representing 33 small credit unions, supports the proposed amendments to Part 741 as a reasonable housekeeping measure to reduce regulatory complexity. However, they argue that the proposal offers only marginal benefits and urge the NCUA to focus on more substantive deregulation, such as reducing examination frequency and over-compliance pressure.

An individual commenter supports the NCUA's proposal to simplify regulations by removing redundant cross-references. They argue that streamlining the language will improve accessibility and ease of compliance for smaller credit unions without changing substantive requirements.