The Defense Credit Union Council (DCUC) has been busy lately, firing off comment letters to the National Credit Union Administration (NCUA) like they’re going out of style.
The topic? Three separate regulatory proposals that could reshape how credit unions operate. Let’s break down what they said and why it matters.
Updating Rules That Are Old Enough to Rent a Car
First up: the Depository Institution Management Interlocks Act, or DIMIA for those who don’t enjoy typing out lengthy acronyms. The NCUA wants to bump the asset thresholds to $10 billion, and DCUC is here for it. Why? Because the current thresholds were set back in 1996—when dial-up internet was cutting-edge and you probably owned at least one flannel shirt.
Financial institutions have grown significantly since then, and DCUC argues it’s time the rules caught up with reality. The proposed change would ease regulatory burden while still preventing the biggest players from forming anticompetitive management interlocks. That’s bureaucrat-speak for “keeping the big institutions from working together in ways that hurt competition.”
DCUC particularly likes that the proposal creates a single $10 billion threshold for both institutions involved. Simple, predictable, and aligned with what other federal financial regulators are doing. Consistency is a beautiful thing.
But Don’t Throw Out the Good Stuff
Here’s where DCUC pumped the brakes. The NCUA also proposed eliminating something called the “rebuttable presumption” that protects management interlocks involving institutions led by women and minority groups. DCUC said not so fast.
Their reasoning? The NCUA hasn’t shown how removing this protection would actually improve supervision or reduce burden. Translation: if it ain’t broke and it’s helping promote diversity in leadership, why fix it?
Reformatting Rules: Missing the Forest for the Trees?
The second comment letter tackled the NCUA’s plan to change how share insurance requirements are formatted in their regulations. DCUC supports the agency’s broader effort to cut red tape—who doesn’t?—but they’re concerned this particular proposal misses the mark.
The problem? The reformatting wouldn’t actually reduce compliance burden in any meaningful way. Even worse, it could eliminate helpful cross-references that credit unions currently use to navigate the regulatory maze. DCUC essentially said, “We appreciate the effort, but let’s focus on changes that actually make life easier.”
Their recommendation: hold stakeholder roundtables and listening sessions to identify which regulations are genuinely creating unnecessary headaches. In other words, ask the people who deal with these rules every day what would help most.
Federal Credit Unions Get the Green Light on Interchange Fees
The third letter addressed what might be the most consequential issue of the bunch: federal credit union authority to collect interchange fees from payment card operations.
DCUC came out swinging in support of the NCUA’s interim final rule, which clarifies that federal credit unions absolutely have the authority to assess and receive these fees. This isn’t creating new powers—it’s confirming what’s been true under the Federal Credit Union Act all along.
Why does this matter? Because some states (looking at you, Illinois) have tried to restrict interchange fees through their own legislation. The NCUA’s rule affirms that federal law trumps state laws that interfere with federally authorized payment card activities.
“Varying state restrictions on interchange fees and payment processing could undermine the uniform national payments framework relied upon by consumers, businesses, and military communities,” explained Jason Stverak, DCUC Chief Advocacy Officer. “The interim final rule provides important legal certainty for federal credit unions and appropriately preserves the integrity, efficiency, and reliability of the nation’s payments system.”
Why Credit Unions Should Care
These might sound like inside-baseball regulatory discussions, but they have real-world implications. Interchange fees help credit unions cover the costs of providing payment card services. Without clear authority to collect them, credit unions could face financial pressure that ultimately gets passed on to members through higher fees or reduced services.
Anthony Hernandez, DCUC President and CEO (and retired U.S. Air Force Colonel), emphasized the bigger picture: “We strongly support reforms that reduce unnecessary burden, provide greater regulatory clarity, and preserve the federally granted authorities credit unions rely upon to deliver affordable financial services.”
DCUC didn’t mince words in their conclusion, urging the NCUA Board to “adopt the interim final rule as final without modification.” Given the uncertainty created by state laws like Illinois’s Interchange Fee Prohibition Act, they argued the NCUA had clear justification to act quickly and decisively.
The Bottom Line
The DCUC is playing its role as industry advocate, supporting regulatory updates that make sense while pushing back on changes that could create more problems than they solve. It’s a balancing act—embrace modernization where it helps, but don’t sacrifice protections or clarity in the process.
For credit unions navigating an increasingly complex financial landscape, having clear rules and federal backing makes all the difference. These comment letters represent an effort to ensure that the regulatory framework evolves in ways that actually benefit the institutions serving millions of members nationwide.