Empty board room. Credit/Shutterstock
America’s Credit Unions is urging the NCUA to revisit and revise its newly finalized succession planning rule, citing concerns about its prescriptive nature and potential unintended consequences for federally chartered credit unions.
In a comment letter submitted to the agency, the trade group acknowledged the importance of leadership continuity but expressed reservations about the final rule adopted under Part 701.4 of the NCUA’s regulations. “While we strongly support the principle of succession planning, we urge the NCUA to revisit this final rule in the future,” the organization stated.
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America’s Credit Unions warned that the rule, as written, risks being overly rigid and may not account for the diversity of credit union sizes, structures, and governance models. The Board has broad authority to oversee and examine credit unions, and while ensuring leadership continuity is a priority, overly prescriptive requirements could result in operational burdens or compliance challenges, particularly for smaller institutions, the group explained.
The final rule requires federally chartered credit unions to document and maintain succession plans as part of sound governance practices. While the NCUA said the regulation is designed to strengthen institutional resilience, some in the industry argue it may have the opposite effect if not implemented with appropriate flexibility.
America’s Credit Unions called on the agency to continue engaging with credit union stakeholders to better understand how the rule is applied in practice and to consider potential refinements. “We encourage the NCUA to gather feedback from the industry post-implementation and revise the rule as needed to ensure it supports effective, not burdensome, governance,” the letter said.
The group also reiterated its support for regulatory modernization overall and encouraged the NCUA to maintain transparency and collaboration in future rulemakings.
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Editor-in-Chief at CU Times. To connect, email at [email protected]. As Editor-in-Chief of CU Times since 2016, Michael Ogden has led the editorial team in all aspects of content strategy and execution, including the creation of the publication’s exclusive and proprietary research database of the credit union industry’s economic landscape. Under Michael’s leadership, CU Times has successfully shifted to an all-digital editorial product with new focuses on the payments, fraud, lending and regulatory beats. Most recently, he introduced a data-focused editorial product for subscribers that breaks down credit union issues into hard data, allowing for a deeper and more factual narrative for readers. In 2024, he launched the "Shared Accounts With CU Times" podcast, which offers a fresh, inside-the-newsroom perspective through interviews with leaders from the credit union industry and the regulatory world. He dives into pressing credit union issues, while revealing the personalities working behind-the-scenes to push the credit union world forward. His background includes years as a radio and TV anchor/reporter and a public relations and digital/social media manager, where he covered the food and music industries, as well as cooperatives and credit unions. Over the years, he has launched numerous exclusive video and podcast series, including a successful series of interactive backstage interviews with musicians at music festivals, showcasing his social media and live streaming production skills.
