The NCUA Board in July agreed to solicit comment on a plan to close the stabilization fund in September, That could result in a Share Insurance Fund distribution to federally insured credit unions of between $600 and $800 million.

The stabilization fund had been scheduled to close in 2021.

Under federal law, the stabilization fund has been used to provide the agency with the ability to mitigate costs from stabilizing the corporate credit union system.

At the same time, the NCUA board agreed to seek comment on a plan to increase the normal operating level of the Share Insurance Fund from 1.30% to 1.39%.

NAFCU said the two NCUA plans would ensure that the agency would not charge an insurance fund premium this year. However, it would eat into the dividends credit union otherwise receive and would result in an “unjustifiable” retention of credit union funds.

"In addition, we respectfully ask the NCUA for a delay regarding the proposed fund merger, as the proposal is being unnecessarily rushed," Berger said. "Credit unions were required to deliver funds to the stabilization fund after five corporate credit unions failed – even those having no capital investments in the corporate credit unions – and they all deserve to be made whole."

NAFCU also is troubled with the legality of keeping stabilization funds in the share insurance fund and the way they will be returned to credit unions.

"NAFCU members and staff have exhaustively reviewed and analyzed NCUA's proposal,” Berger said. “ NAFCU strongly supports credit unions receiving full rebates from corporate stabilization assessments as soon as possible, but there are too many questions as to the true impact of the NCUA's plan to support it at this time.”