NEWS: Yesterday, The League submitted four comment letters to the NCUA, telling them that we back each of the proposed regulatory changes in Round 3 of their Deregulation Project:
- We wrote a letter in support of the NCUA’s proposal to rescind its Interpretive Ruling and Policy Statement (IRPS) 08-2, issued in 2008. In that IRPS, the NCUA updated and clarified its operational policies for serving “underserved areas.” The current requirements for service to underserved areas are stated in Chapter 3 of the NCUA’s Chartering Manual, which is published in its entirety in Appendix B to Part 701 of the NCUA regulations. Rescinding the IRPS would not add, remove, clarify, or otherwise change the substantive requirements already established in the Federal Credit Union Act and the Chartering Manual.
- We told the NCUA that we support its proposal to remove part 701.31 from its regulations. That section, labeled “nondiscrimination requirements,” is outdated and may be confusing. It was intended to summarize the Fair Housing Act (FHA) prohibitions on discrimination related to real estate related loans, appraisals, and advertising. It has not been amended since 2001 and so it may not reflect all case law or regulatory developments under the FHA, a statute that primarily falls under the jurisdiction of the Department of Housing and Urban Development and continues to apply to federal credit unions (FCUs) regardless of the NCUA’s regulations. The change would not impact credit unions’ compliance obligations regarding the FHA and the Equal Credit Opportunity Act, but it would lessen confusion, since the provision to be rescinded has not kept pace with the law.
- We voiced support for an NCUA proposal to eliminate IRPS 10-1, regarding community chartering policies for FCUs. This information can be found in the NCUA’s Chartering and Field of Membership Manual, which is published in its entirety in Appendix B to Part 701 to the NCUA regulations. The change would eliminate a redundant standard currently listed in more than one area. This would ease the compliance burden on federal credit unions. Only two Wisconsin-based credit unions are FCUs, but one Wisconsin state-chartered credit union wrote to explain why it would like to see this proposal finalized: “While the rescission directly eases the compliance burden for federal credit unions, the resulting streamlining and modernization of the regulatory framework benefits all credit unions.”
- We wrote a letter in support of the NCUA’s proposal to rescind IRPS 11-02. Issued in 2011, the IRPS sets forth the requirements and process for chartering corporate federal credit unions. This information can be found in the NCUA’s Chartering and Field of Membership Manual, which is published in its entirety in Appendix B to Part 701 of the NCUA’s regulations. We favor this change because it would reduce regulatory burdens by limiting the sources that FCUs must check when chartering a new corporate credit union, ensuring that they need only comply with the guidance and procedures in the Federal Corporate Credit Union Chartering Manual.
Thank you to the credit unions that answered our Comment Call and shared their feedback on these proposals, especially Kohler Credit Union.
Help us comment on Round 4
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 4 by March 23, 2026, so that our comment letter (which is due March 30, 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.