Support for changes to NCUA’s supervisory committee audit, verification regulations
Calling them “common-sense updates,” America’s Credit Unions is backing the NCUA’s proposed updates to Part 715 that modernize supervisory committee audit and verification requirements while maintaining strong oversight and examiner access. In addition to the Part 715 letter, America’s Credit Unions submitted comments on two other proposed actions that are part of NCUA’s Deregulation Project.
In a comment letter sent to the agency Monday, Regulatory Advocacy Senior Counsel Luke Martone said the proposal appropriately removes overly prescriptive and outdated provisions that no longer reflect how credit unions and auditors operate today. Specifically, efforts to modernize the definition of “internal control,” update account verification requirements to align with how records are actually maintained, streamline engagement letter requirements, and eliminate duplicative audit-report submission obligations are positive changes.
The letter urged the NCUA to take additional steps to further modernize Part 715. These suggested updates include clarifying that account verifications may be conducted using electronic and system-based methods, removing outdated terminology, and updating audit working paper requirements to reflect current audit practices.
The other two letters address deleting appendices in NCUA rules about safeguarding member information and responses to unauthorized access to member information. Both would be issued as guidance in the form of a letter to credit unions.
America’s Credit Unions recommends NCUA undergo a notice and comment period if any substantive changes are made during each process, and that NCUA ensure a smooth transition to avoid industry confusion.
America’s Credit Unions will continue to engage the agency in response to the many proposals offered as part of its Deregulation Project.