Although your July 16 article "Will Only the Big Dogs Survive" was wide-ranging and timely, its unfortunate contextual omission may leave your readers with an incomplete picture of what I conveyed to Mr. Jim Jerving during my interview.
The article correctly states that I was asked if it is a fair assessment that NCUA has added regulations in a variety of areas without taking steps to eliminate others. Unfortunately, only a portion of my response was quoted when I said: that while "NCUA is charged to enforce, it has no control to issue regulations."
We all know NCUA has the ability to issue regulations. In my comment, I was referring to regulations issued by other regulators, such as the Federal Reserve Board, the Department of the Treasury and the Federal Trade Commission and laws such as the Truth in Lending Act, the FACT Act and BSA. That narrow point should not be construed as an assertion that NCUA is somehow inactive or powerless to affect the regulatory regime facing credit unions.
My view is in fact very much to the contrary. NCUA has within its purview a number of tools to carefully calibrate the regulations under which credit unions operate, and to make certain that they perform their mission in a safe and sound manner, without unnecessary, duplicative or burdensome rules. For example, NCUA conducts an annual review of one-third of our regulations with an eye toward simplifying or eliminating redundant or burdensome regulations.
More recently, at the June board meeting the board adopted a revised Prompt Corrective Action proposal to align credit unions' capital requirements with other federal regulated institutions and to provide credit unions additional flexibility in their calculation and use of capital. Similarly, at the May meeting the Board issued proposed changes to the Chartering Manual to clarify and streamline the community chartering process.
The regulatory process requires significant attention to detail, particularly in understanding the way in which various statutes and regulations intersect. I am committed to continued vigilance in looking for opportunities to improve the overall regulatory landscape for all credit unions.
Gigi Hyland, Board Member
NCUA, Alexandria, Va.
