ABA Opposes NCUA's Equitable Sharing of TCCUSF Expenses Proposal

In a comment letter filed with National Credit Union Administration (NCUA), ABA opposed the NCUA’s proposed amendment to its corporate credit union regulation that would require all corporate credit unions members -- both federally insured and non-federally insured -- to share the Temporary Corporate Credit Union Stabilization Fund’s expenses equally.

Under the proposal, the NCUA Board would ask non-federally insured corporate members to make voluntary payments to the TCCUSF when the board assessed a fund premium on federally insured corporate members. If a non-federally insured member declined to make the requested payment, or made a payment for a lesser amount, the corporate credit union would hold a vote on whether to expel the member.

ABA opposed the proposed amendment because it shifts a portion of the TCCUSF’s cost from federally insured to non-federally insured corporate members. The comment letter stressed that: the TCCUSF’s creation directly benefited the National Credit Union Share Insurance Fund and federally insured credit unions, not non-federally insured credit unions; the proposed amendment exceeds the NCUA’s statutory authority; and the proposed payment by non-federally insured credit unions to the TCCUSF is neither a gift, nor is it voluntary.

To read ABA's comment letter, click here.