ARLINGTON, Va.-NASCUS called the approach of NCUA’s 2006-2011 Strategic Plan “dynamic and forward thinking” but asked for further recognition of the dual chartering system. NASCUS’ official comment letter, signed by Vice President of Regulatory Affairs Brian Knight, read, “Elements of NCUA’s Strategic Plan 2006-2011 demonstrate a dynamic and forward thinking approach by the agency.However, given the significance of the partnership between state and federal credit union regulators in monitoring the safety and soundness of state-chartered federally insured credit unions, NCUA’s strategic vision for the future should more specifically articulate the goals for maximizing NCUA’s reliance on, and cooperation with, state credit union regulators.” He continued, “While the plan speaks to working with state regulators “to the optimal extent feasible,” few specifics are identified to inform the public how the agency defines this term or what steps will be taken to achieve.” NASCUS also asked NCUA for more quantifiable measures on which to judge the agency’s performance. “Can stabilization in the number of credit unions serve as a measure? Should stakeholders and state regulatory partners be able to draw conclusions based on the number of discretionary joint examinations performed on state-chartered federally insured credit unions? In measuring improved efficiency, is it necessary to compare expenses to the number of insured institutions, or the assets under supervision?” Knight asked. The association, representing state regulators and state-chartered credit unions, also requested a stronger delineation between NCUA’s regulatory and insurance functions; this distinction also goes to the overhead transfer rate, another sore spot between the state and federal regulators. NASCUS noted that all regulators are primarily interested in safety and soundness, even without any insuring authority. “However, the goals and objectives of a chartering regulator may also diverge, or more likely, surpass, those of the insurer.” Specifically, Knight wrote, “Share insurance regulations should be tailored narrowly rather than promulgated broadly. Preemption of state regulatory authority homogenizes the credit union system, stifling innovation and inhibiting flexibility. The NCUA’s strategic plan should reflect awareness of these issues and speak to the agency’s efforts to preserve meaningful dual chartering.”

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