On leases, CUNA said that credit unions' business practices should determine whether obtaining full assignment is appropriate or not. Additionally, CUNA finds the unguaranteed residual value limitation too restrictive at 25% unless the amount over is guaranteed.

CUNA argued against changing credit unions' current privacy notices and said they should no longer be required on an annual basis, particularly for those credit unions that are not required to offer members an option to opt-out.

In addition, Dunn recommended:

-increasing the $250,000 threshold for requiring real estate appraisals;

-requiring the official NCUA signage only on the home page of Internet sites;

-considering appraisal requirements, aggregate construction and development loan limits, minimum borrower equity requirements for certain loans, loan to value requirements, and others as part of a credit union's business policy and not regulation;

-expanding Reg-Flex waivers in the member business lending and leading areas;

-including examples as part of staff commentary in share insurance rules; and

-making the regulatory review notice more prominent on the agency's Web site.

CUNA also urged NCUA to support legislation permitting federal credit unions to operate full service trust departments.

NAFCU Senior Counsel and Director of Regulatory Affairs Carrie Hunt made similar comments regarding leasing and appraisals.

The organization also pointed to the "growing compliance challenges imposed by the litany of new regulations and regulatory amendments that are promulgated annually." Hunt cited findings from NAFCU's June Flash Report data that found 97% of respondents are spending more staff time on compliance issues than five years ago and 95% said they do not expect to spend less time within the next year. While BSA is considered most burdensome, Reg E, PATRIOT Act, and NCUA/FASB auditing standards were also highlighted as "significantly burdensome."

As some NCUA regulations apply to federally insured, state-chartered credit unions, NASCUS also weighed in on regulatory changes the group would like to see, starting with member business lending. "Comment solicitation from the industry and consultation with state regulatory agencies on state specific member business lending rules would both be enhanced if Part 723 clearly identified which provisions were NCUA discretionary rule-making," NASCUS stated.

NASCUS also reiterated its request for NCUA to consolidate all the insurance rules to streamline compliance and reduce unnecessary regulatory burden for state-chartered, federally insured credit unions.

Lastly, NASCUS suggested that NCUA expand the ability of state regulatory agencies to apply for waivers from NCUA insurance rules by submitting state specific rules that do not increase risk to safety and soundness.

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