“CUNA continues to engage with credit unions of all sizes throughout the country to collect feedback within the industry,” the letter reads. “Based on recent communications with credit unions, we have the following policy recommendations for the NCUA to consider. These comments supplement CUNA’s previous communications with you, other members of the NCUA Board, and NCUA staff.”
The recommendations include:
- Expeditiously adopting any needed rule changes to ensure the Central Liquidity Facility’s (CLF) borrowing authority and membership parameters conforms to the CLF provisions passed in the CARES Act;
- Reviewing its existing Prompt Corrective Action (PCA) regulations and to do forbearance on credit unions that may temporarily fall between the 6% and 7% net worth leverage ratio during this pandemic-driven economic crisis;
- Using its regulatory flexibility powers to issue updated examiner guidance that clarifies the agency will grant the maximum regulatory flexibility it has available for handling credit unions;
- Working with the SBA to provide loan forgiveness guidance to credit unions providing PPP loans.
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