WASHINGTON-In its official comment letter regarding the definition of small credit unions, CUNA asked NCUA to consider a much higher ceiling than the agency proposed. The current definition of a small credit union for the purposes of the Regulatory Relief Act of 1980 is credit unions with less than $1 million in assets. NCUA has proposed raising that ceiling to $10 million, which NAFCU is fine with, but CUNA is advocating upping the cap to at least $50 million in assets. CUNA Associate General Counsel Mary Dunn noted that banks have set their ceiling defining a small bank at $150 million. Even at $50 million and above, only 47% of credit unions have a dedicated compliance officer, she explained. Under $50 million, that percentage drops to around 16%. Dunn said that the purpose of the act was to allay lawmakers' concerns that smaller entities "don't have dedicated resources for regulatory compliance." She also pointed out in CUNA's official comment letter that the Federal Reserve Board, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Office of Thrift Supervision and the Small Business Administration have all defined smaller entities as those below $150 million in assets. CUNA recommended including details of the law in the rule. NAFCU Tax Attorney Bill Hall said in an audioconference last week, "We feel that it's a great benefit to credit unions and we support it." Included in this regulation was also the announcement that NCUA plans to notify credit unions in advance what rules the agency intends to review that year as part of its three-year review cycle. NAFCU's comment letter, signed by President and CEO Fred Becker, read, "NAFCU believes such a change is beneficial and will increase public participation in NCUA's rulemaking process." CUNA suggested NCUA publish the list in the Federal Register, as well as its Web site. Dunn also said this should not limit NCUA's ability to create new proposals as necessary. -

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