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America’s Credit Unions (AmCU) has urged the NCUA to modernize or eliminate outdated regulations that increase operational burdens for credit unions without enhancing safety and soundness. In a comment letter submitted Wednesday, AmCU Regulatory Advocacy Senior Counsel Luke Martone detailed several recommendations as part of the NCUA’s voluntary participation in the Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA) review .
The EGRPRA requires federal banking agencies to review regulations every 10 years to identify those that can be streamlined or repealed. Although not legally required to participate, the NCUA conducts its own review to align with the banking regulators. This year’s review focuses on agency programs, capital rules and consumer protection regulations.
AmCU’s recommendations targeted multiple areas:
- Community Development Revolving Loan Fund – Simplify application processes and incorporate regular credit union feedback.
- Central Liquidity Facility – Shorten approval timelines, reinforce that use carries no stigma and make CARES Act enhancements permanent.
- Low-Income Designation – Expand qualification methods, increase transparency and consider lowering the income threshold.
- Capital Adequacy – Modernize standards by lowering the CCULR, easing subordinated debt issuance, adjusting thresholds and tailoring stress tests.
- Consumer Protection Rules – Update nondiscrimination provisions, Truth in Savings disclosures and advertising rules to reflect digital platforms.
- Member Inspection Rights – Preserve the federal framework while curbing abuse by raising petition thresholds, narrowing scope and expanding exemptions.
Martone emphasized that these changes would give credit unions “more flexibility to serve members effectively while maintaining a strong regulatory framework.” The NCUA will consider stakeholder feedback before finalizing any regulatory changes.
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