COMMENT CALL: In 2025, the National Credit Union Administration (NCUA), along with other federal agencies, began a major initiative to review, and revise (as appropriate) all its regulations. The agency wants public input to help with this review, which is designed to ensure that all NCUA rules “are focused on the safety, soundness, or resilience of credit unions.”
So far, the NCUA is proposing to change or remove eight regulations that it considers obsolete; that duplicate statutory requirements; that are intended to serve as guidance, not requirements; or that are overly burdensome. The NCUA has published two rounds of regulatory relief proposals, each focusing on four rules.
The League may comment on these proposals, depending on the feedback we receive from Wisconsin’s credit unions. Please reach out to Paul Guttormsson at The League with your reactions to or thoughts about any of the proposals listed below. We will be sure that our comments reflect your views. Our letters will not identify the credit unions that offer their input to us.
The NCUA’s Deregulation Project page includes details on each of the proposals summarized below.
Round One
Please email Paul Guttormsson with your thoughts on this round of regulatory relief proposals by Feb. 2, 2026, so that our comment letter (which is due Feb. 9, 2026) can reflect your positions.
- Supervisory Committee Audits and Verifications. The NCUA is proposing to amend its regulations governing supervisory committee audits to eliminate unnecessary, redundant, and overly prescriptive provisions.
Impacts on credit unions: The changes would let federally insured credit unions (FICUs) and auditors apply current, industry-accepted frameworks for evaluating internal controls; end the requirement to verify members’ accounts against the records “of the treasurer” and state more generally that members’ accounts must be verified against the credit union’s records; remove an overly prescriptive requirement that the engagement letter for an outside auditor must be signed by both parties; remove a sentence that requires a supervisory committee to provide NCUA with a copy of audit reports upon request (since the NCUA has the authority to access all FICUs’ books and records); and remove two sentences from the rules that describe the objective of a financial statement audit compelled by NCUA.
- Guidelines for Safeguarding Member Information. The NCUA is proposing to remove Appendix A to part 748, “Guidelines for safeguarding member information,” from its regulations. Appendix A sets standards for FICUs to protect the security and confidentiality of customer records and information and to protect against unauthorized access to or use of such records. The contents of Appendix A would be published as a Letter to Credit Unions.
Impacts on credit unions: The change would not alter the expectations for FICUs to safeguard member information, but it would allow for more efficient revisions, streamline the NCUA’s regulations, and ensure that guidance is conveyed as guidance.
- Guidance on Response Programs for Unauthorized Access to Member Information and Member Notice. The NCUA is proposing to remove Appendix B to part 748, “Guidance on response programs for unauthorized access to member information and member notice,” from its regulations. Appendix B gives FICUs guidance for creating programs to address and respond to instances of unauthorized access to member information. The contents of Appendix B would be published as guidance.
Impacts on credit unions: The change would not alter the expectations for FICUs to respond when member information is accessed without authorization, but publishing it as guidance would “be a better vehicle for conveying and updating this information and will help to streamline NCUA’s regulations,” the NCUA has said.
- Corporate Credit Unions. The NCUA is proposing to amend its regulations for corporate credit unions by removing the requirement that a corporate credit union’s asset and liability management committee must have at least one member who is also a member of the corporate credit union’s board of directors. It would also remove filing and notification requirements related to a corporate credit union’s annual report and any management letter or other report issued by its independent public accountant.
Impacts on corporate credit unions: Corporate credit union boards would have the ability to determine their ALCO membership. The change would also reduce burdens on board members. Eliminating these filing requirements would remove unnecessary and unduly burdensome requirements on corporate credit unions.
Round Two
- Surety and Guarantor Requirements: The NCUA is proposing changes to remove the segregated deposit and collateral requirements when a FICU acts as a surety and guarantor. Removing this regulation will provide FICUs with greater flexibility to design products that meet members’ needs. FICUs would remain subject to the other requirements regarding surety and guaranty agreements.
Impacts on credit unions: Credit unions would have the flexibility to manage surety agreements without overly burdensome requirements for managing collateral. They also would be able to determine the types of collateral they would accept, market value, and method for securing an interest in the collateral that they choose to obtain.
- Limits on Loans to Other Credit Unions: The NCUA is proposing to remove the regulations related to approval and policies on making loans to other credit unions. While this provision would no longer be codified in regulation, federal credit unions would remain subject to statutory requirements related to making loans to credit unions. Federally insured, state-chartered credit unions would remain subject to any other applicable NCUA or state law or regulation.
Impacts on credit unions: Credit unions would be able to reduce the number of lending policies they would need to manage and approve.
- Catastrophic Reporting: The NCUA is proposing to extend the deadline for a FICU to report a catastrophic act to 15 calendar days, require notice to NCUA rather than notice to the appropriate regional director, and replace the prescriptive recordkeeping list with a requirement to prepare a record that contains the basic facts of the event.
Impacts on credit unions: This change would: modernize the reporting process and provide greater operational flexibility for FICUs, which may help smaller credit unions operating under emergency conditions; give credit unions experiencing a catastrophic act more time to stabilize operations and assess the full scope of damage; make calendar days easier to calculate when determining compliance; and give FICUs the ability to reduce undue regulatory burden while still maintaining a record of events.
- Accuracy of Advertising and Notice of Insured Status: The NCUA is proposing to remove the requirements for a credit union to include an official NCUA advertising statement in their advertising and marketing materials. “The requirements are highly prescriptive, inflexible, and not well suited to modern advertising,” according to the NCUA. This change would not amend requirements related to displaying the official sign.
Impacts on credit unions: Removing this provision would mean credit unions would have fewer rules to comply with when advertising, marketing, and developing incidental promotional items. It would also reduce confusion about which rules apply to credit union advertisements.