ARLINGTON, Va. (3/9/10)--The National Credit Union Administration (NCUA) will need to balance reconsideration of regulatory oversight of the corporate system with the ability of the system to recapitalize going forward, said the National Association of State Credit Union Supervisors (NASCUS), in a comment letter Friday about NCUA's proposed rule, Part 704, Corporate Credit Unions. NASCUS is also seeking enhanced joint federal and state oversight as well as state law preservation over certain areas of corporate regulation and governance, the letter said. During the rulemaking process, NASCUS state regulators worked with NCUA to provide the state regulatory system's perspective. NASCUS commended NCUA for moving forward toward a final rule and made these recommendations:
* Restore diversity to the corporate system by allowing state regulations to vary from NCUA's section 704; * Provide state regulators access to federal corporate credit union books and records; * Amend the proposed Prompt Corrective Action (PCA) provisions to mirror the natural person credit union PCA provisions regarding consultation and cooperation with state regulators; * Limit governance provisions to federal corporate credit unions; and * Promulgate the stress testing and asset liability management provisions as thresholds rather than inflexible limits.
NASCUS--as did the Credit Union National Association in its comment letter to NCUA--identified legacy assets as a critical area to consider. (See related story: "With tweaks, NCUA corporate plan protects system.") For NASCUS' full comment letter, use the link.