Tuesday, June 2, 2020

NCUA Should Publish Its Analysis

In a May letter to credit unions, the National Credit Union Administration (NCUA) stated that it will no longer exclude military personnel with APO and FPO mailing addresses from calculating whether a credit union qualifies for low-income designation.

This decision was based upon analysis by the agency's Office of Chief Economist, which determined that the majority of military personnel would qualify as low-income members.

However, NCUA has not published the analysis of the Office of Chief Economist.

If NCUA had subjected this action to the rulemaking process, it would have had to disclose details of this analysis.

The agency needs to make public its analysis. It should also make public the data behind the analysis.


2 comments:

  1. Seems like a bit of overkill when the Agency only wants to exclude members who were being improperly evaluated previously, no?

    All the new rule states is the foreign military members will be assigned a proper address so they can be evaluated correctly instead of immediately excluded.

    ReplyDelete
    Replies
    1. I filed a Freedom of Information Act (FOIA) request for the analysis performed by NCUA's Office of Chief Economist. NCUA denied my FOIA request in a July 10 letter.

      Delete

 

The content is provided for educational purposes only, with the understanding that neither the authors, contributors, nor the publishers of this site are engaged in rendering legal, accounting or other expert or professional services. If legal or other expert assistance is required, the services of a competent professional should be sought.

Comments appearing in response to articles appearing on this site do not necessarily reflect the views of the ABA. ABA makes no representations regarding the truth or accuracy of commentary or opinions that may be posted in response to the articles that appear on this website.

The inclusion herein of any link to a website, either in the text of an article or in a comment, does not denote any approval, sponsorship, or endorsement by the ABA, and ABA is not responsible for the content or opinions expressed on those linked websites or related commentary. This content is not licensed to third parties sites and is not affiliated with any third party site. Any reference to the author or this content on any third party site on the Internet is not authorized by the ABA.

It is the policy of the American Bankers Association to comply fully with all antitrust laws. Certain discussions should be considered off-limits, including those that contain competitively sensitive data such as price and cost information, or statements that could be construed as reflecting an attempt or desire to control or influence a particular market or markets. Future pricing or other prospective competitive information should never be shared.