Just what constitutes small? NCUA defines it as any credit union with less than $1 million in assets, but has proposed raising that figure to $10 million in assets. But CUNA is urging the agency to expand the definition of small to $50 million in assets or less.
At issue is the threshold at which NCUA is required to conduct an analysis of the effect of its proposals and final rules. In a comment letter to the agency, CUNA has asked NCUA to consider that only 47% of credit unions with assets of more than $50 million have a paid compliance director and that smaller CUs have considerably less personnel.
In its letter the trade group said it supports NCUA efforts to review its definition of "small entities" to determine whether more credit unions should be covered by NCUA's analyses under the Regulatory Flexibility Act (RF Act). But it said its own review indicates NCUA should raise the threshold, noting that only 16% of credit unions with assets of up to $50 million have a full-time staff whose work is devoted exclusively to regulatory compliance.