Status: Comment period closes on June 22, 2026

NPRM Summary: The NCUA Board (Board) is proposing to amend its regulations governing the merger of insured credit unions into banks. The Board proposes to eliminate certain prescriptive procedural, disclosure, and communication requirements. This action is necessary to reduce unnecessary regulatory burdens and provide credit union boards of directors with greater flexibility to exercise their business judgment. The intended effect of these changes is to ensure members receive clear and effective disclosures while simplifying compliance for credit unions, reducing administrative costs, and modernizing the conversion process.

Link to full proposal: https://www.federalregister.gov/public-inspection/2026-07806/bank-conversions-and-mergers-merger-of-insured-credit-unions-into-banks

Simplified Summary: The Board proposes to amend 12 CFR part 708a, subpart C, which governs the merger of insured credit unions into banks and provides a procedural framework for transactions that fundamentally alter a credit union’s charter or structure. The rule establishes procedural and substantive requirements to protect the interests of credit union members during such mergers. Key provisions in the regulation include the mandatory determination of the credit union’s “merger value,” comprehensive disclosure requirements to members, and a structured voting process.

The Board proposes to eliminate several provisions that are overly prescriptive and impose undue burdens on a credit union’s board of directors during merger deliberations. 

These reductions in requirements will result in mergers that are less costly for the members and just as informative.

Proposed Changes to Rule: The Board proposes to reduce regulatory burden and increase flexibility by eliminating some procedural, disclosure, and communications requirements for converting insured credit unions to mutual saving banks.

Change 1: Remove the definition of “clear and conspicuous” from 12 CFR 708a.301. This definition mandates specific formatting, such as bold type and a minimum 12-point font size. The Board believes this level of prescription is unnecessary and can hinder effective communication.

Impact on Credit Unions: Removing this definition would allow credit unions the flexibility to design disclosures that are effective and clear for their members.

Change 2: Revise the newspaper publishing requirement in 12 CFR 708a.303(b)(1). This requirement may no longer be most effective for communication in the digital age and may pose unnecessary costs. The proposal would require the notice to appear on the credit union’s homepage, if they have one.

Impact on Credit Unions: This proposal would eliminate an outdated and potentially costly requirement. It would also make pre-board-vote notices more accessible to members who can find that information directly on the homepage of the credit union’s website.

Change 3: Revise the due diligence reporting requirements in 12 CFR 708a.304(d). This change would remove the requirement for the board to describe how the board located the merger partner and negotiated the merger agreement in its submission to the NCUA. The Board believes that requiring a narrative on these specific internal processes is overly intrusive and micromanages the board’s deliberative functions.

Impact on Credit Unions: This proposed change would streamline the reporting requirements, focusing on the substantive outcome of the board’s decision-making process.

Change 4: Remove highly prescriptive formatting requirements in 12 CFR 708a.305(e)(2). This provision dictates that certain text must be placed in a box on the front of a single, otherwise blank piece of paper and placed at a specific point in the notice package. This does not necessarily result in better member comprehension.

Impact on Credit Unions: Eliminating these specific formatting rules would reduce administrative burden.

Change 5: Remove plain language determining factors in 12 CFR 708a.305(f). The examples of specific factors to consider in determining whether a communication to members is in plain language are redundant with the requirement that communications be simple and easy to understand.

Impact on Credit Unions: Compliance would be simplified, and credit unions would have more flexibility in their merger communications.

Change 6: Remove “Voting guidelines” from 12 CFR 708a.312. The guidelines are non-binding suggestions to help a credit union obtain a fair and legal vote. Removing this section will streamline the regulatory text, making it clearer for credit unions to understand their legal duties.

Impact on Credit Unions: This proposal would remove guidance from the regulation to clarify what is actually required.

12 CFR 711.3(c) and 12 CFR 711.6(b)(2) – Thresholds Increase for Major Assets Prohibition of the Depository Institution Management Interlocks Act Rule

Status: Comment period closes on July 6, 2026

NPRM Summary: The NCUA Board (Board) is seeking comment on a proposed rule that would increase two thresholds in its regulation implementing management official interlocks for purposes of the Depository Institution Management Interlocks Act (DIMIA). DIMIA provides that the NCUA may adjust, by regulation, the major assets prohibition thresholds to allow for inflation or market changes. This proposal would increase both major assets prohibition thresholds to $10 billion to account for changes in the United States banking market since 1996. Additionally, the proposal would remove a presumption related to depository institutions controlled or managed by persons who are members of a minority group or women.

Link to full proposal: https://www.federalregister.gov/public-inspection/2026-09009/thresholds-increase-for-the-major-assets-prohibition-of-the-depository-institution-management

Simplified Summary: The Depository Institution Management Interlocks Act (DIMIA) is a federal law that fosters competition by prohibiting a management official of a depository organization from serving as a management official of another, unaffiliated depository organization to avoid possible anticompetitive effects. DIMIA has three specific prohibitions, one of which relates to the asset size of the two organizations. This prohibition, called the major assets prohibition, is intended to capture circumstances in which the two organizations are large enough that the management interlock between them may have an anticompetitive effect, even when the institutions are not in the same community. DIMIA provides that the NCUA may adjust, by regulation, the major assets prohibition thresholds to allow for inflation or market changes.

The Board proposes to increase the major assets prohibition thresholds for management interlocks. Under current 12 CFR 711.3(c), you must get an exemption if:

* You are a management official of a depository organization with assets exceeding $2.5 billion, and
* You intend to serve as a management official of an unaffiliated depository organization with assets exceeding $1.5 billion. 

The proposal would increase both thresholds to $10 billion.

12 CFR 711.4(c) allows a credit union management official to hold similar positions at another credit union. DIMIA prohibitions in 12 CFR 711.3(c) only apply to credit unions when a management official also serves as a management official at a different type of depository institution, like a bank or thrift.

The Board also proposes to remove 12 CFR 711.6(b)(2), which outlines instances in which NCUA would presume that an interlock would not result in a monopoly or substantial lessening of competition for institutions. These presumptions relate to instances when an organization seeking to add a management official is a depository organization that:

* Primarily serves low-and moderate-income areas; 
* Is controlled or managed by minorities or women; 
* Has been chartered for less than two years; or
* Has been determined to be in troubled condition. 

DIMIA prohibitions were established to allow certain organizations to bypass monopoly concerns when appointing management officials. NCUA now considers this presumption too broad and potentially conflicting with Equal Protection standards established by the U.S. Constitution. 

Proposed Changes to Rule

Change 1: Increase the major assets prohibition thresholds for management interlocks in 12 CFR 711.3(c). The Board proposes increasing the exemption thresholds to $10 billion (currently $2.5 billion and $1.5 billion, respectively) to account for inflation and growth in the banking market. This change will also align NCUA’s regulations with the thresholds established for banks.

Impact on Credit Unions: Fewer depository institutions would need to seek an exemption from NCUA, reducing regulatory burden. This proposed change may make it easier for credit unions with $10 billion or less in assets to find qualified directors by removing the need to file exemption requests. Finally, setting the two thresholds at the same level will streamline NCUA’s DIMIA regulations and simplify determination of whether depository organizations are subject to the major assets prohibition.

Change 2: Remove presumption in 12 CFR 711.6(b)(2). The Board proposes to eliminate the presumption an interlock won’t result in a monopoly or substantial lessening of competition in certain instances.

Impact on Credit Unions: This proposal would reduce the risk of Equal Protection issues associated with 12 CFR 711.6. Further, this proposal streamlines interlock requirements for credit unions by simplifying the requirements related to major asset prohibitions on management interlocks.

12 CFR 741 – Requirements for Insurance

Status: Comment period closes on July 6, 2026

NPRM Summary: The NCUA Board (Board) is publishing this proposed rule to amend its regulations governing requirements for share insurance. This proposed rule would eliminate numerous provisions that merely point to substantive provisions codified elsewhere in the NCUA’s regulations. The intended effect is to simplify the regulatory text and make it easier to navigate without altering the compliance obligations of federally insured credit unions. The Board believes this action is necessary to streamline the agency’s regulations and reduce regulatory complexity.

Link to full proposal: https://www.federalregister.gov/public-inspection/2026-09010/requirements-for-insurance

Simplified Summary: The NCUA Board is proposing a rule to streamline its share insurance regulations. The sections that are proposed for removal primarily refer federally insured state-chartered credit unions (FISCUs) to other NCUA regulations. These proposed changes are intended to reduce duplication.

This proposal would not affect compliance with insurance requirements for FISCUs.

Impact on credit unions: This proposed rule will streamline NCUA’s regulations by removing sections that only serve to reference other, substantive regulations.