When a federal regulator shrinks its staff by nearly a quarter and then asks for more money, it owes the public an explanation.
That’s the core of what the Defense Credit Union Council (DCUC) told the National Credit Union Administration (NCUA) about its proposed 2027-2028 budget.
Elizabeth A. Eurgubian, a partner at Atlas Advocacy LLC, delivered the testimony on November 17, 2026, on behalf of DCUC. The group represents defense and veteran credit unions that serve military members, veterans, and their families. It says it wants a strong, independent NCUA that regulates well and protects the Share Insurance Fund. Overall, it backs the agency’s supervisory direction. It also has several suggestions for making the budget better.
The first concerns the numbers. NCUA’s authorized positions have dropped 23 percent since 2025, which DCUC sees as a chance to move from an examination-heavy model to a technology-enabled, risk-based one. Yet the draft budget calls for a 2.9 percent increase in 2027 and another 5.8 percent in 2028. Some costs don’t shrink with headcount, and DCUC acknowledges that. Still, it wants the agency to show how a smaller operation is actually saving money. The industry has also shrunk: federally insured credit unions fell from 4,533 in June 2024 to 4,214 in June 2026. DCUC thinks the budget should reflect that, and it suggests lengthening the intervals between exams for CAMELS 1 and 2 credit unions (the top-rated, healthiest ones) without weakening supervision or putting the Share Insurance Fund at risk.
Travel is the second target. The 2027 travel budget would fall $2.7 million, or 13.6 percent, to $17.4 million. But the 2028 figure climbs to $18.9 million, up 8.7 percent, blamed on inflation and an agency-wide training event. DCUC wants the NCUA to rethink what it truly needs, given fewer staff, a reorganization, electronic processes, and risk-based exams. Its specific ideas: require cost-benefit justifications for travel unrelated to exams, combine meetings and training where possible, do more training virtually, and send examiners on-site based on risk. The question to answer, in DCUC’s view, is whether current practices are necessary or just habits left over from a bigger agency.
Third, DCUC wants to know how much money goes to consumer protection examinations. The Office of Consumer Financial Protection’s proposed 2027 budget is down 10 percent from 2026, but it’s unclear how much of that actually funds exams. The council asks for a breakdown of consumer protection exam resources versus other supervisory work. Its reasoning is that credit unions need a level playing field with the larger banks and fintechs overseen by other agencies.
Fourth, several offices are getting notable increases: the Office of the Executive Director (66.3 percent), the Office of Ethics Counsel (22 percent), the Office of Human Resources (20.6 percent), and the Office of the Inspector General (16.4 percent). DCUC asks the NCUA to lay out what these offices need and how the extra money supports efficiency, risk-based supervision, and the reorganization.
There’s one exception to the scrutiny. DCUC wants the Office of External Affairs and Communications protected, since it took deep cuts last year. The office reports directly to the NCUA Chair, which keeps external messaging aligned with the Chair’s priorities. With the agency reorganizing and filling vacancies, DCUC argues this is the wrong moment to weaken a function that keeps lines open with industry, Congress, and other regulators.
Fifth, DCUC strongly supports the budget’s emphasis on technology modernization, cybersecurity, and artificial intelligence. But it wants those investments to make exams easier for credit unions, not simply generate more data transfers and reporting. The priorities it names are streamlining exam procedures, eliminating duplicate reporting, and making supervision more consistent.
Finally, there’s contracted services. Even as internal staff shrinks, that budget rises sharply from 2026 to 2028. DCUC understands much of the jump comes from using less unspent prior-year surplus to offset the 2027 budget, but it challenges the NCUA to find other uses for those funds. If contractors are the most cost-effective way to get specialized expertise, DCUC is fine with that. If work is simply shifting from staff to contractors, undoing earlier streamlining, the council wants the agency to see what can be done in-house, cut duplicate services, and explain how contracting improves efficiency after the workforce reduction.
DCUC closed by thanking the NCUA Board for its collaboration and for the chance to comment, and said it looks forward to more outreach.
Why should you care? NCUA’s budget is funded by the credit unions it oversees, so costs that rise faster than the agency shrinks eventually land on the institutions serving members like you. If you bank with a credit union, especially one built for service members and veterans, a leaner regulator that spends carefully and supervises by risk is good news. It means more of your credit union’s resources can go toward serving you.