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Michigan Credit Union League Home » Information Services » Publications » News Articles  

NCUA Extends Small CU Definition Comment Deadline   (Misc News: October 23, 2012)

At the urging of CUNA, the NCUA board has approved a one-month extension of the comment period for the proposed rule updating the definition of a “small entity.”

The original public comment period was scheduled to close Oct. 26. However, some interested parties have indicated they needed additional time to prepare and submit comments. The new deadline will be Nov. 26. CUNA's Small Credit Union Committee recently urged the agency to extend this deadline by at least 30 days.

CUNA Deputy General Counsel Mary Dunn said CUNA and credit unions appreciate the NCUA's move to grant an extension.

"Given the heavy load that credit unions have right now in attempting to respond not only to NCUA, but to other regulators, such as the CFPB, about proposed, important regulations, the agency's action gives credit unions an opportunity to be more thorough in their commentary," she told CUNA News Now.

The board voted at its September meeting to issue a proposed rule updating the definition of a “small entity” under the Regulatory Flexibility Act to include federally insured credit unions with assets below $30 million. The threshold increase would require NCUA to specifically determine and consider the impact of proposed and final rules on approximately 1,600 additional small credit unions, raising the total number of credit unions that receive special consideration to more than 4,000. The proposed rule also removes these additional small credit unions from the scope of NCUA’s final interest rate risk management rule and risk-based net worth requirements under Prompt Corrective Action.

CUNA maintains that a credit union with up to $100 million in assets could reasonably be considered "small," and has encouraged the agency to raise the threshold to at least $50 million.

MCUL has released a Comment Call on this issue: 12-CC-21. Please submit your thoughts on this proposal to Veronica Madsen, director of regulatory affairs at MCUL Comment Calls and Comment Letters can be found on MCUL’s web site,

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