Supporting NCUA’s DIMIA proposal to simplify regulations

NCUA’s proposed update to increase the major assets prohibition thresholds in its regulation implementing the Depository Institution Management Interlocks Act (DIMIA) would provide needed updates to thresholds that haven’t changed since 1996. The update has America’s Credit Unions’ support, as reflected in a comment letter sent Monday.

The DIMIA major assets prohibition generally prevents a management official of a depository organization with total assets above $2.5 billion from serving at the same time as a management official of an unaffiliated depository organization with total assets above $1.5 billion.

NCUA’s proposal would raise both thresholds to $10 billion.  

The letter notes this would align NCUA with other federal banking agencies (which raised the thresholds to $10 billion in 2019), simplifying the regulations and making it easier for institutions to determine if the prohibition applies.

“The change will also reduce regulatory burden. Based on the data in the proposal, raising the lower threshold to $10 billion would exempt 289 credit unions from the major assets prohibition, leaving only 20 credit unions subject to it as of Dec. 31, 2024,” reads America’s Credit Unions’ comment letter. It continues that removing currently required file exemption requests would make it easier for exempted credit unions with less than $10 billion in total assets to “recruit and retain qualified directors and other management officials.”

Read the full letter