Recommendations on outdated, unnecessary, overly burdensome NCUA regulations

October 9, 2025

The NCUA has several opportunities to reduce regulatory burdens and address outdated, unnecessary, and unduly burdensome regulations.  In comments filed Wednesday, America’s Credit Unions Regulatory Advocacy Senior Counsel Luke Martone details those recommendations with the agency.

The outreach is in connection with the Economic Growth and Regulatory Paperwork Reduction Act, which requires federal banking agencies to conduct reviews every 10 years of regulations that can be eliminated or streamlined. The NCUA is not statutorily required to conduct such a review, but it does so voluntarily.

This year’s review covers agency programs, capital, and consumer protection categories of regulations.

America’s Credit Unions makes recommendations in the following areas:

  • Community Development Revolving Loan Fund: Streamline the burdensome application process and seek regular CU input to better align funding with needs.
  • Central Liquidity Facility: Shorten approval timelines, reinforce that CLF use carries no stigma, and support restoring CARES Act enhancements (corporate credit union agent authority) permanently.
  • Low-Income designation: Expand qualification methods, increase transparency, and consider lowering the income threshold.
  • Capital adequacy: Reiterating much of what was included in a recent letter sent to the NCUA, the NCUA should modernize capital standards by lowering the CCULR, ease subordinated debt issuance, adjust thresholds, and tailoring stress tests.
  • Nondiscrimination: Remove or revise credit union-only restrictions and overly broad appraisal liability standards inconsistent with the Fair Housing Act.
  • Truth in Savings: Update disclosure rules for digital channels and clarify fee disclosures.
  • Advertising and insured status: Modernize signage and disclosure rules for digital/mobile platforms and social media.
  • Member inspection rights: Preserve federal framework but control abuse by raising petition thresholds, limiting scope, and expanding exemptions.

Read the full letter