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Modernizing charters, cutting “phantom” barriers and ending the ‘Mother May I’ era

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By William Wille, managing editor, The Credit Union Connection

At its board meeting this morning, the National Credit Union Administration (NCUA) illustrated how it is navigating the balance between a long-term agency reorganization and immediate efforts to streamline how credit unions operate and interact with the regulator.

Chairman Kyle Hauptman began his remarks by saying it has been one of his priorities to start a new credit union. He highlighted the overall progress being made by the Consumer Access and Processing and Reporting Information Systems (CAPRIS) and Credit Union Resources and Expansion (CURE) teams to update the charter application system and streamline the requirements for applying for a new credit union charter.

Frequently asked questions (FAQs) related to brokered and reciprocal deposits

Frank Kressman, General Counsel from the Office of General Counsel, provided a briefing on a new FAQ regarding brokered and reciprocal deposits. Kressman and Chairman Hauptman were pretty blunt in saying the purpose of this FAQ was “to offer regulatory clarity for federally insured credit unions (FICUs), confirming that participation in brokered and reciprocal deposit networks is permitted,” and to remove any “phantom barriers” for FICUs to participate. 

Although brokered and reciprocal deposits have been going on for decades, and none of the information in the FAQs is new, credit unions were waiting for a green light that was already on. NCUA just had to point at it.

Chairman Hauptman questioned, “Why was this perfectly approved thing not happening?” He followed up by asserting the NCUA has a problem with innovating; this is a broader NCUA issue of “Mother May I” and is a “cancer” on the system.

“We are not encouraging action. We are not encouraging inaction. Reciprocal deposits are permissible.” 

However, a critical reminder was that NCUSIF only applies to member deposits. For non-low-income credit unions, these deposits must still align with Field of Membership (FOM) requirements to qualify for pass-through insurance.

NCUA Deregulation Project

Next up was Amanda Parkhill, acting director for the Office of Examination and Insurance, with an update on the ongoing NCUA Deregulation Project.

As part of Phase 1 of the Deregulation Project, NCUA reviewed all regulations and identified those that were the least disruptive, quick wins (rules that contradict newer statutes or were mistakenly labeled as guidance), and, as Parkhill indicated, fit into the buckets of those that were:

  • Obsolete;
  • Duplicative;
  • Intended to serve as guidance, not requirements; or
  • Overly burdensome.

A key part of this “spring cleaning” is stripping out guidance mistakenly attached to formal rules in the Federal Register. This clarifies for both examiners and credit unions that you cannot violate guidance, as it lacks the force of law.

Since the December 2025 launch of the Deregulation Project, NCUA has issued 29 Notices of Proposed Rulemaking and has received more than 230 public comments, which respondents have largely supported. 

With nearly 4,300 FICUs, that is a low number of comments! Now is the time to put your experience on the record on: 

* Bank Conversions 12 CFR 708a, NCUA-2026-0266
* Mergers & Insurance, 12 CFR Part 708b, NCUA-2026-0267
* FOM Housekeeping IRPS 06-1, NCUA-2026-0265

Comments are still open until next Monday, April 13! Check out our Advocacy page for more details and links to comment.

Credit union leaders are also encouraged to provide feedback via the “Ask NCUA” portal to ensure these changes actually achieve their intended purpose.

Parkhill concluded her report, saying the NCUA will continue implementing the Genius Act, with a focus on establishing the necessary rules and frameworks for credit union subsidiaries and stablecoin issuers.

Regarding stablecoins, the Chairman issued a specific warning: even if a credit union or CUSO owns a subsidiary, it is not covered by the NCUSIF.

In addition to the Genius Act and deregulation efforts, she announced a joint rulemaking with the FDIC and OCC on the Bank Secrecy Act and anti-money laundering programs for financial institutions, including banks and credit unions.

Hauptman noted that removing “Reputation Risk” as a standalone category is intended to eliminate subjective oversight. While legitimate risks like legal or insider abuse remain under other categories, this move prevents the term from being used as a “catch-all” for examiner agendas.

NCUA is also reviewing comments on a proposed rule that would prohibit reputation risk as a separate category in exams. Instead, examiners are required to point to specific, measurable issues, such as legal or operational failures. Another proposal would allow dependent care reimbursement for board members. 

2026-2030 Strategic Plan

The 2026-2030 Strategic Plan and the 2026 Annual Performance Plan were shaped by the agency’s first-ever strategic planning town hall, in which 550 stakeholders participated.

The Three Strategic Goals:

  • Safeguard FICUs: Utilizing risk-focused supervision to protect the Share Insurance Fund (SIF).
  • Enable Access & Innovation: Fostering the safe adoption of financial technology (including the Genius Act and Stablecoins) and reducing barriers to chartering.
  • Strengthen Agency Performance: Implementing the internal reorganization by 2027 to align business units and improve accountability.

Operational Transparency and SIF Health

The meeting concluded with a push for greater transparency in agency reporting. Chairman Hauptman requested that the NCUA website be updated to include a “Date Published” column for all reports, ensuring stakeholders can easily find the most recent guidance.

Some Quick Stats on the NCUSIF:

  • Equity Ratio: 1.30% (While a SIF performance update is due in mid-May, the Equity Ratio is only calculated twice a year and will remain at 1.30% until the June reporting cycle.)
  • Net Income: $113.8 million (Q4 2025)
  • Failures: Zero federally insured credit union failures in Q4 2025.

The next update will be in mid-May.

NCUA’s Philosophical Bent

The meeting’s underlying message was a call for credit unions to stop asking for “affirmative permission.” As the Chairman put it, “If the speed limit is 50 mph, we shouldn’t have to put out that 49 mph is okay.” 

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