As Prepared for Delivery on February 18, 2021
This final rule simply formalizes what has been a long-standing practice for CUs and the NCUA. As a practical matter, we have been doing this all along. I’m glad to see it codified in the rule.
I’d like to see more of this great work by NCUA staff, in codifying these sorts of things and putting them into the affirmative. If you’ve talked to a compliance officer at a small institution, you know the position they are in. It can be a thankless job, a bit like playing the position of goalie in hockey or soccer, when the only time they are the focus is when things aren’t going well for their team. They want to see it stated that something is ok. It’s not enough to NOT see a rule against something, they need it stated that something is in fact acceptable.
On a related note, I understand that, coincidentally, the Part 745 share insurance rules are part of NCUA’s annual Regulatory Review Process where the agency examines a third of our existing regulations for consistency, accuracy, and clarity. This is a huge undertaking, and I want to thank the staff for the excellent work done throughout the year. Too often, changes do not get made until problems arise. I appreciate the proactive approach staff have taken to maintain the integrity of NCUA regulations.
Mr. Chairman, this concludes my remarks. Thank you.