Credit union trade organizations picked apart the NCUA's Overhead Transfer Rate methodology during a public comment period that ended April 26.

The OTR determines what percentage of the NCUA's operating budget will be drawn from the National Credit Union Share Insurance Fund and used to cover expenses related to federal share insurance. In August 2015, the NCUA announced it would publish and seek comment on its OTR methodology for the first time in January 2016.

Comments on the agency's website were primarily written by state credit union agency and league leaders, including NASCUS president/CEO Lucy Ito, who called the NCUA's OTR methodology seriously flawed in a 20-page letter.

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