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NCUA Proposes to Revise 'Small Entity' Definition
Tuesday, May 5, 2015 6:25 AM

A National Credit Union Administration proposal to revise the definition of "small entity" to apply to federal credit unions with less than $100 million in assets has the support of CUNA and CUNA's Small Credit Union Committee. The definition applies to NCUA Regulatory Flexibility Act (RFA) analysis and regulatory relief.

In a comment letter submitted to the agency Monday, CUNA President/CEO Jim Nussle and Small Credit Union Committee Chair Debie Keesee also urged the NCUA to adjust this threshold on an annual basis by an index that continues to capture a percentage of the smallest credit unions.

CUNA supports regulatory relief for all credit unions. "Nonetheless," the letter notes, "we feel the smallest credit unions are particularly vulnerable to even the least burdensome regulatory changes, such as new call report requirements."

According to CUNA research, 57 percent of credit unions in the United States operate with 10 or fewer full-time equivalents, and anecdotal data gathered by CUNA suggests many employees of small credit unions face 70- and 80-hour work weeks to run day-to-day business and keep up with constant regulatory changes.

CUNA also added in its letter that the organization supports "decoupling" the RFA threshold from the threshold for credit unions that receive resources and assistance from the NCUA's Office of Small Credit Union Initiatives (OSCUI). CUNA supports the OSCUI threshold remaining at $50 million in assets to ensure those credit unions can continue to receive those resources.