Earlier this week, an NCUA 2013 White Paper, "National Credit Union Share Insurance Fund (NCUSIF) Improvements," was released to the public outlining the agency's legislative pursuit for broadening its authority to administer the NCUSIF. This paper is clearly yet another piece of NCUA's agenda for mitigating perceived risks within credit unions – an agenda the agency continues to keep credit unions in the dark about, despite multiple requests from stakeholders, such as NAFCU. 

Since 2013, we have seen the NCUA roll out various initiatives to address the same perceived risk in our industry. These include the agency's current risk-based capital proposal and its recent final rules on emergency liquidity and stress testing.  As if these regulatory regimes weren't enough, the NCUA is now turning its attention to the Hill to seek broader authority to administer the NCUSIF, including the ability to assess risk-based share insurance premiums. The one common factor among all these initiatives is that credit unions were the last to know.

Prior to the white paper's release, the NCUA's legislative pursuit for reforming the NCUSIF was only publicly revealed as a buried footnote in the agency's recent testimony before the Senate Banking Committee. Credit unions deserve a more open and transparent relationship with their regulator. They deserve a chance to be part of the discussion, rather than have it dictated to them in a rulemaking or legislation.