The 40 or so comment letters filed about the NCUA’s methodology for determining the Overhead Transfer Rate was a healthy total of comment letters.

However, what was overwhelming about the OTR letters filed is the consistency of the messages they contained. The first message: Action must be taken by NCUA to correct a flawed system of determining how the NCUA operating budget is funded from the NCUSIF.

The letters filed have come from a broad cross section of the credit union movement. Both national trade associations have weighed in, along with state trade groups (from north to south, and east to west), state regulators, state credit unions, individuals and other organizations.

With little or no exception, these letters urge the agency to make changes to the current system – and ensure a fair allocation of costs to both state and federally chartered credit unions.

Complete your profile to continue reading and get FREE access to, part of your ALM digital membership.

Your access to unlimited content isn’t changing.
Once you are an ALM digital member, you’ll receive:

  • Critical information including comprehensive product and service provider listings via the Marketplace Directory, CU Careers, resources from industry leaders, webcasts, and breaking news, analysis and more with our informative Newsletters.
  • Exclusive discounts on ALM and CU Times events.
  • Access to other award-winning ALM websites including and

Already have an account?


© 2023 ALM Global, LLC, All Rights Reserved. Request academic re-use from All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.


Credit Union Times

Join Credit Union Times

Don’t miss crucial strategic and tactical information necessary to run your institution and better serve your members. Join Credit Union Times now!

  • Free unlimited access to Credit Union Times' trusted and independent team of experts for extensive industry news, conference coverage, people features, statistical analysis, and regulation and technology updates.
  • Exclusive discounts on ALM and Credit Union Times events.
  • Access to other award-winning ALM websites including and

Already have an account? Sign In Now
Join Credit Union Times

Copyright © 2023 ALM Global, LLC. All Rights Reserved.