ARLINGTON, Va. -NCUA's Notice of Proposed Rulemaking on specialized lending activities “is sound” says NASCUS, but in the association's comment letter it filed on the NPR the association says it may be “unnecessarily broad causing regulatory burden.” “Given the robust regulatory oversight for state-chartered, federally insured credit unions, the proposed rule should be amended to reduce regulatory burden on those credit unions whose management expertise satisfies the risk mitigation standards of state and federal regulators,” NASCUS' comment letter reads. NASCUS suggests NCUA accept the decision of the state regulator in determining a credit union's risk mitigation under the rule – the NPR would make the waiver proposal a two-part step for state-chartered credit unions since they'd have to seek a waiver from both the state regulator and the federal. “Accepting the state regulator's approval of a waiver would streamline the process for state credit unions and help mitigate the broad sweep of the rule,” NASCUS' comment letter states. Lastly, concerning the NPR's exception for third-party services that are wholly-owned subsidiaries of federally insured CUs, NASCUS explains that state credit union laws and regulations may allow CUs to jointly own service providers with other entities which are examined by state credit union authorities. While not “wholly-owned” as detailed in the NPR, NASCUS asks NCUA to amend the rule to include these entities. “NCUA should amend the rule to allow state service organizations that by the nature of their majority credit union ownership and examination by state authority, present a reduced risk level to the same extent as wholly-owned subsidiaries,” NASCUS states in its comment letter.