NCUA should work to fix a regulatory disparity that leaves credit unions with an uneven playing field when it comes to an extended examination cycle, CUNA President/CEO Jim Nussle wrote to NCUA Chairman J. Mark McWatters. The recently enacted S. 2155 increases the asset limit below which depository banks are eligible for an 18-month exam cycle to $3 million, while credit unions must fall under $1 billion in assets to be eligible.

“This regulatory disparity now serves as a comparative advantage for community banks. Congress has already delegated authority to NCUA to set the frequency of examinations for credit unions,” Nussle wrote. “Given that Congress has now codified an extended exam cycle for community banking institutions—the type of insured bank depository institution most closely aligned with the credit union industry—NCUA would be well within its legal purview to exercise similar discretion for small credit unions.”

Already, credit unions are concerned that NCUA has not taken steps to address the increased commercial appraisal thresholds the banking agencies adopted back in April,” Nussle wrote, nothing that NCUA acted to rectify a disparity in advertising rules earlier this year. “These competitive advantages given to banks translate into tangible costs for credit unions … Credit unions deserve the privilege of providing customer service subject to comparable regulatory supervisory thresholds as applied to banking organizations.”

CUNA strongly supports NCUA’s efforts and advancement toward exam modernization, including long-term goals of continuous supervision and remote examinations.