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Michigan Credit Union League

MCUL Comments on Five NCUA Regulatory Proposals

MCUL & Affiliates recently submitted comments to the NCUA on five regulatory topics, all generally positive in nature for credit unions, but some which could go much further.

The proposals included:

  • raising the asset threshold in NCUA’s definition of “small entity” from $10 million to $30 million;
  • expanding the definition of “rural district” for field of membership purposes to potentially allow inclusion of population hubs;
  • extension of the time period that a credit union is given to accept an offered LICU designation, from 30 to 90 days;
  • an ANPR on improving the rule governing payday alternative loans; and allowing federally chartered credit unions to invest in TIPS. 

MCUL acknowledges the intent behind the proposals and the potential benefits they will provide to credit unions, but also proposed some alternative concepts. For example, on the small asset size threshold, both MCUL and CUNA urged the agency to consider using the Small Business Administration’s threshold for RFA analysis, in similar fashion as other federal financial institutions regulators – a higher ceiling that would afford fair regulatory relief to more institutions that need and deserve such.

For more information on MCUL’s comment calls and letters, contact Kieran Marion, vice president of governmental affairs, at

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