ARLINGTON, Va. — In response to Small Business Administration's request for nominations for existing regulations that are in need of reform, NAFCU reiterated a number of areas for consideration.

The SBA's Office of Advocacy's Regulatory Review and Reform Initiative, or r3, is designed to identify and address existing federal regulations that should be revised because they are ineffective, duplicative, or out of date.

NAFCU suggested reforming Regulation D, which implements the reserve requirements for depository institutions pursuant to the Federal Reserve Act by increasing the six transfer limitation, wrote Dan Berger, NAFCU senior vice president of government affairs, in a Dec. 28 letter to SBA.

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NAFCU said it also is concerned that it is becoming "increasingly costly and burdensome" for credit unions to adhere to the Bank Secrecy Act and Anti-Money Laundering law and regulation. Credit unions should not be charged with policing unlawful Internet gambling, Berger added.

NAFCU said it also supports efforts to simplify and improve the process for obtaining mortgages under the Real Estate Settlement Procedures Act. Regarding consumer protection Regulations Z and E, which, addresses the Truth in Lending Act and the Electronic Fund Transfers Act, respectively, the trade association recommended streamlining requirements.

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