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Higher small CU threshold needed at SBANCUA CUNA
WASHINGTON (11/15/12)--More credit unions could see their regulatory burdens ease if the Small Business Administration goes through with its proposal to raise the size standard to $500 million for a credit union to be considered a small entity, the Credit Union National Associatin (CUNA) wrote in a Nov. 13 comment letter.

Raising the threshold from its current level of $175 million would enable more credit unions "to benefit from provisions that require federal agencies to assess and minimize regulatory costs for smaller entities, including the Regulatory Flexibility Act (RFA) and the Small Business Regulatory Enforcement Fairness Act (SBREFA),'' wrote CUNA Deputy General Counsel Mary Mitchell Dunn.

She noted those credit unions with assets under $500 million generally have fewer human resources to address their large and growing regulatory burdens and most do not have a full-time compliance officer on their staff. Raising the threshold would increase the percent of credit union and bank assets under the threshold from 3.5% today to 8.6%. 

As required by the Small Business Jobs Act of 2010, the SBA must conduct a detailed review of at least one-third of the size standards that apply to small businesses every 18 months.

Dunn also urged the SBA and its Office of Advocacy to support a substantial increase in the threshold that the National Credit Union Administration (NCUA) uses to define "small entity," NCUA's equivalent of "small business." NCUA's size standard, $10 million, has not been revised since 2003 and the NCUA is seeking comments now on how its size standard should be revised.  

Dunn said CUNA favors having the NCUA set the size standard at the same level as SBA and supports having the NCUA review the standard every 18 months. CUNA has communicated those views to the NCUA via a separate letter.

She also urged the SBA and Office of Advocacy to continue to actively participate in the SBREFA review process and do all they can to urge the Consumer Financial Protection Bureau to minimize costs for smaller credit unions that result from new or existing regulations.


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