The NCUA should not act rashly when making changes in the structure of the corporate credit union system and work with state regulators to "refine" the concentration of risk so that some of it is less concentrated, NASCUS wrote the agency.
In a letter written by NASCUS President/CEO Mary Martha Fortney, the association suggests the creation of a joint federal-state examination team to annually examine corporates deemed to a "material systemic risk."
NASCUS also recommended that corporates be mandated to retain higher capital reserves, including risk-based capital. It opposes limiting corporate charters to a specific payment services or investment services function.
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