When asked whether CUNA is optimistic about the prospects for the agency initiating a moratorium, CUNA Senior Vice President and Deputy General Counsel Mary Mitchell Dunn said,  "Hope springs eternal."

In his letter to Matz, Cheney also urged the agency to only issue regulations that address safety and soundness concerns, unless required by law to issue other ones. He also recommended that the NCUA seek input before issuing a rule about whether the rule is needed to address existing problems or "whether other approaches could be reasonable."

He also recommended that the agency provide the results of its cost-benefit and legal analyses of potential regulations. Too often, credit unions are left guessing about the legal justification for a rule and don't know if the agency has properly weighed how much a rule will cost credit unions, he noted.

Dunn said the Consumer Financial Protection Bureau has so far been good about reaching out to credit unions and their trade groups to give input on regulations before they are issued. She hopes that the NCUA follows that example more.

At an Oct. 31 House subcommittee hearing, Royal Credit Union Chief Operation Officer Mark Willer put a human face on the impact of regulations.

"The regulatory pendulum has swung so far that financial institutions are faced with eliminating services or charging for them to offset the cost and increased regulatory burden of providing them. Many of the new regulations are intended to address abuses in the financial marketplace or prevent unethical financial practices that harm consumers," he said. "Yet, I would challenge any member of this committee to find a single local community credit union or community bank that has been accused of such practices."

Willer, who testified at a Wausau, Wis., field hearing of the House Financial Services Committee's subcommittee on consumer credit and financial institutions, noted that his credit union had to hire an additional compliance specialist to deal with all the new rules. This brings the total number of employees who deal with compliance to five (in addition to outside parties) at the $1.8 billion Eau Claire, Wis.,-based credit union.

NCUA spokesman David Small didn't address the specific comments raised in CUNA's letter or the testimony but said in an email that the agency is "in the process of summarizing all the regulatory relief comment letters received and will provide some recommendations for the board to initially review and consider (but not for immediate action) this month. This valuable feedback will be taken under consideration and is part of a larger, deliberate effort at regulatory modernization at NCUA."

In his letter, Cheney also reiterated some of the association's previously addressed concerns about the examination process. He urged the agency resolve disagreements before issuing a document of resolution or letter of understanding and agreement and to improve ways for credit union executives to discuss concerns about their CAMEL ratings and other issues with NCUA personnel.

Cheney also suggested that the agency instruct examiners not to enforce agency guidance as if it were a regulation and not to interpret regulations that are implemented by other agencies.