Records preservation proposal would keep focus on vital actions

NCUA’s records preservation proposal—issued in the seventh round of its Deregulation Project—would provide important updates to the regulation. In comments filed Monday, America’s Credit Unions requests that NCUA finalize the rule with several clarifications.

Specifically, the proposal would make clarifications and updates to better align the regulation with current records management practices. 

In the letter, America’s Credit Unions supports the proposal to keep the rule focused on vital records needed to restore member services after a catastrophic event, rather than using it as a broader record retention rule.

Removing Appendices A and B would provide relief because they were intended as guidance but have often been treated as mandatory, the letter adds.

Clarifying that older versions of vital records may be destroyed unless another law or regulation requires retention, and that identifying a record as “vital” does not mean it must be kept permanently.

America’s Credit Unions also recommends:

• Useful parts of the appendices should be updated and maintained separately as clearly nonbinding guidance, FAQs, or training materials.
• Recognizing modern records practices, including electronic logs, automated backups, third-party providers, and documented procedures, rather than requiring manual record-by-record processes.
• Flexibility for credit unions of different sizes and operations, especially small credit unions with limited staff and storage resources.

Read the full letter