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Regulatory Call to Action
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The Association values your input regarding NCUA's proposed changes to the definition of a small credit union.
Dear Credit Union Advocate,

Below is a call to action on a proposed rule. The association would like your input on a notice of proposed rulemaking. Your comments will help inform our conversations with regulators and will add membership perspective to our comment letters. Although the Association has consistently commented on behalf of credit unions on the CFPB’s proposal, credit unions are encouraged to review the proposal and weigh in directly with the bureau.  
About this proposed rule
Small Credit Union Definition - Proposed changes to the definition of small credit union
The proposed rule redefines the definition of a small credit union - revising the current $10 million asset size to $30 million. As proposed this rule would result in regulatory relief, access to grants, loans, and technical assistance that will benefit approximately 1600 additional credit unions.
Agency: NCUA
Agency Due Date: November 26, 2012
Read the Federal Register Notice
Read Debie Keesee's Draft Letter
Read the Anthem Article

The proposed rule redefines the definition of a small credit union – As proposed the small credit union definition rule would require the NCUA to determine and consider the impact of proposed and final rules on approximately 1,600 additional small credit unions that are above the current $10 million asset size but below the proposed $30 million. One example of regulatory relief for small credit unions is the exemption fromthe final interest rate risk management rule and risk-based net worth requirements.  

Besides the regulatory relief, small credit unions benefit from access to loans, grants and technical assistance through NCUA’s office of Small Credit Union Initiatives.

The proposed rule also commits the NCUA Board to review and consider adjusting the threshold every three years.

Although the Association has consistently weighed in on behalf of credit unions on NCUA proposals, we suggest that you review the proposal for its applicability on your credit union and weigh in with the NCUA. The NCUA is taking comments through November 26. Comments can be submitted electronically or you can take our survey:

Via email to: regcomments@ncua.gov
ATTN Mary Rupp, Secretary of the Board

Or, via mail to: Mary Rupp
Secretary of the Board
National Credit Union Administration
1775 Duke Street
Alexandria, VA 22314

Alternatively, you can send your thoughts and observations to jtrull@nwcua.org by November 22, for inclusion in the Association’s comment letter.
The NWCUA Regulatory Advocacy team works with state and federal regulators to help reduce the regulatory burden on credit unions and protect the credit union movement. The Association encourages members to participate in the regulatory process. If you have any questions on these or any regulatory issues, please contact Director of Regulatory Advocacy John Trull at jtrull@nwcua.org, or at 800.995.9064 x209.
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