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NASCUS’ comment letter filed on EGRPRA suggested that NCUA reorganize its regulations to create a section specifically pertaining to all of the rules and regulations regarding federal insurance rather than the numerous cross-references it currently contains. “While this may seem an easy enough task, for smaller credit unions it adds a level of burden that is unnecessary,” NASCUS’ comment letter read. It continued, “Reorganizing NCUA’s regulations to create a section of insurance rules that contains all of the rules and regulations pertaining to federal insurance would carry costs for the federal regulator.However, any cost to the federal regulator should be weighed against the burden to small credit unions of having to connect the regulatory dots of the current incorporation by reference approach of Part 741, Subpart B. The federal regulator is best able to bear the cost of reorganizing the rules and regulations to simplify compliance for small credit unions.” [email protected]

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