ALEXANDRIA, Va. — Comment letters that came into NCUA on its records preservation proposed regulation generally supported the rule change, but said some allowances should be made for smaller credit unions.
"While the proposal retains language from the current rule providing flexibility to credit unions in terms of the format they chose for maintaining records, requiring updating of accounts on a daily basis for small non-automated credit unions may be problematic and we encourage the agency to reconsider the impact of this requirement on such institutions," CUNA Deputy General Counsel Mary Dunn wrote in the group's comment letter.
NAFCU's letter pointed out that the term "business day" when determining when to report a "catastrophic event" to NCUA should be defined specifically for this regulation to cover only those days a credit union is actually open for business. "Under the proposed rule, NAFCU is concerned that a credit union that is open only for part of the week will be required to report to NCUA even if members services are not affected by the catastrophic event triggering the reporting requirements," it read.
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The comment letters submitted to NCUA were mixed on whether to include past letters to credit unions and alerts in the regulation as an appendix or otherwise. Some felt they could be enforced as regulation while others thought the issues were already addressed. However, Educational Systems Federal Credit union President/CEO Chris Conway called the appendix "a valuable tool."
CUNA did express concern that recommendations for restoring services in the regulation could lead to confusion between examiners and credit unions as they are not requirements. "Recommendations in our view should be included in guidance or 'best practices' information rather than in the body of the regulation," Dunn wrote. A similar scenario could come from recommendations regarding duplicate records.
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