NEWS: The League submitted four comment letters on behalf of Wisconsin credit unions today, telling the NCUA that we support each of the proposed regulatory changes in Round 2 of their Deregulation Project.
Below are brief summaries of each proposal and our comments.
- Accuracy of Advertising and Notice of Insured Status. The NCUA proposed to remove the requirements for credit unions to include an official NCUA advertising statement in their advertising and marketing materials.
Our letter quoted feedback from one Wisconsin credit union: “The current advertising statement rule is highly prescriptive and often difficult to apply in space-limited formats such as short videos, social posts, and mobile banners. Eliminating this requirement better aligns regulation with how members engage with information today, without altering the obligation to display the official NCUA sign in branches and digital account-opening channels.” We went on to suggest that the NCUA do what it can to consolidate all insurance‑related disclosure requirements into a single unified publication.
- Catastrophic Act Reporting. The NCUA’s proposal would: 1) Extend the deadline for a federally insured credit union (FICU) to report a catastrophic act to 15 calendar days; 2) Require notice to NCUA rather than notice to the appropriate regional director, and 3) Replace the prescriptive recordkeeping list with a requirement to prepare a record that contains the basic facts of the event.
The League’s letter quoted one of our member credit unions that shared its reasons for supporting these changes, saying: “These updates reflect operational realities during disasters and ensure timely, consistent regulatory awareness without forcing incomplete data or duplicative outreach when resources are constrained. In the first days after a catastrophic event, credit union teams are prioritizing safety, core system availability, vendor coordination, and member access. A 15-day window allows stabilization and fact-gathering, improving the accuracy of our report and reducing rework and follow-up corrections.”
- Limits on Loans to Other Credit Unions. The NCUA’s proposal would remove paragraph (b) from §701.25 of its regulations. That paragraph requires the boards of directors of all federal credit unions (FCUs) and FISCUs to approve all loans to other credit unions and to establish written policies for managing the associated credit risk.
Although none of the Wisconsin credit unions that answered The League’s comment call said that they make loans to other credit unions, our letter reflected support for keeping the statutory standard while removing duplicative, prescriptive policy mandates in regulation. “This preserves safety and soundness while reducing the document-driven burden.”
- Suretyship and Guaranty; Segregated Deposit and Collateral. The NCUA’s proposal would remove the segregated deposit and collateral requirements when a FICU acts as a surety and guarantor.
Our letter shared a statement from one Wisconsin credit union, which told us: “Greater flexibility in this area gives federally insured credit unions flexibility to design products that meet member needs without compromising the broader requirements that ensure safety and soundness. We view this update as an enhancement [that will provide] operational agility while maintaining appropriate safeguards.”
Thank you to the credit unions that answered our Comment Call and shared their feedback on these proposals.
Help us comment on Round 3
The deadline for commenting on the next round of the Deregulation Project is coming up. For details on the four proposals in this upcoming round, please see this League Comment Call.
Please email Paul Guttormsson with your thoughts on Round 3 by March 1, 2026, so that our comment letter (which is due March 16, 2026) can reflect your positions.
Compliance Roundtable – April 1 (Webinar)
Join a member of The League’s compliance team as they lead a discussion on the latest changes in regulations and need to know information to keep your credit union in compliance. You can find more information or register on our website.