The Defense Credit Union Council (DCUC) has submitted comments in support of the National Credit Union Administration’s (NCUA) proposed rule to allow federal credit unions to reimburse dependent care costs for volunteer officials.
In its comments, DCUC voiced that the proposal would provide needed flexibility for institutions operating under unique demands, including across multiple time zones.
“We appreciate the NCUA’s efforts to modernize its regulatory framework while maintaining the safety and soundness of the credit union system,” said Jason Stverak, DCUC chief advocacy officer.
DCUC expressed strong support of the NCUA’s proposed rule to enable FCU [federal credit union] boards to provide reimbursement of reasonable dependent care costs incurred by volunteer officials:
“This rule is an excellent example of modernizing regulations for today’s environment as it would enable FCU boards to establish policies that allow for the reimbursement of reasonable dependent care costs incurred by volunteer officials while attending board meetings and performing official duties. DCUC agrees with this change because it will provide FCU’s with greater flexibility to create better work-life balance for volunteer officials, thereby encouraging greater and broader involvement with the credit union industry.”
DCUC noted that the proposal appropriately balances flexibility and oversight by allowing FCU boards to establish and manage their own reimbursement policies, subject to supervisory review. DCUC added that dependent care reimbursement should be treated as a reasonable expense tied to official duties, not compensation, and can be verified through standard documentation such as receipts or invoices.
“Credit unions that can attract the best possible board members for leadership positions create a foundation for success, which contributes to the safety and soundness of the credit union system,” DCUC wrote. “This proposed rule would give FCU boards the discretion to adopt written policies that provide for the reimbursement or direct payment of dependent care costs. Therefore, such payments would not be mandatory and an FCU board of directors may adopt a more stringent policy or prohibit such reimbursement entirely.”
DCUC also highlighted that dependent care is a common barrier to volunteer participation, particularly for military and dual-income households managing irregular schedules. The proposed rule would help broaden the pool of qualified board members and strengthen credit union governance.
America’s Credit Unions also sent a letter to the NCUA in support of its dependent care proposal. The letter, penned by Regulatory Advocacy Senior Counsel Luke Martone, highlights that the proposal reflects our organization’s 2024 request that the NCUA clarify that dependent care expenses are reimbursable for volunteer officials.
The letter outlines other aspects of the proposal that are supported by credit unions:
- The proposal appropriately confirms that dependent care costs can qualify as “reasonable and proper” reimbursable expenses under the FCU Act and section 701.33 of NCUA’s regulations, and are not compensation when subject to existing safeguards.
- Allowing reimbursement helps ensure volunteers are not required to bear caregiving costs to serve, which is especially important for smaller credit unions with limited resources.
- The proposal properly preserves board discretion to determine whether and how to reimburse these costs, maintaining flexibility while keeping existing guardrails in place.