NCUA should match recent OCC, FDIC exam reforms

To relieve credit union regulatory burdens so they can better serve their members and communities, America’s Credit Unions wrote NCUA Chairman Kyle Hauptman Thursday, asking for parity with two recent actions taken by the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC).

The OCC announced effective Jan. 1, 2026, it is eliminating mandatory OCC policy-based examination requirements for community banks to reduce supervisory burden and better align OCC practices with risk-based supervision. Both agencies have also proposed to define the term “unsafe or unsound practice” to focus on material risks to a financial institution and generally require an imprudent act to be likely to harm the institution’s financial condition. 

America’s Credit Unions Head of Regulatory Advocacy James Akin thanked Hauptman for his “leadership in steering the NCUA toward a more thoughtful, risk-focused approach to examinations and supervision,” especially his emphasis on clarity, proportionality, and supervisory consistency.

“To keep credit unions at parity with banks, we urge the NCUA to issue a letter embracing the OCC’s examination reforms and to undertake a rulemaking aligned with the interagency proposal on unsafe or unsound practices and MRAs,” he wrote, adding the steps will “prevent competitive disadvantages and ensure examiners concentrate on the issues of greatest consequence.” 

Akin asks Hauptman to:

• Match recent OCC/FDIC reforms and start a parallel rulemaking so credit unions aren’t put at a competitive disadvantage;
• Make exams truly risk-based by ending blanket checklists, defaulting to more off-site work, and cutting duplicative data requests by using existing filings first;
• Decide when to conduct exams on issues like flood insurance, fair lending, Servicemembers Civil Relief Act, and similar areas on actual risk rather than calendar-based timing, and do follow-ups when warranted by risk;
• Define “unsafe or unsound practice” in the same way bank regulators propose, tied to material financial harm, and limit formal findings to legal violations or issues that meet that bar; and
• Create a nonbinding “examiner observations” category for suggestions, and make clear that missing a target date or declining a suggestion won’t trigger enforcement unless there is a legal violation or truly unsafe practice. 

The letter also addresses recent remarks from OCC Comptroller Jonathan Gould about an unlevel playing field between banks and credit unions, noting that community bankers indicate in their own words that other banks are their primary competition, not credit unions. 

Read the full letter