NACUSO's Comment Letter to NCUA's Proposed Amendment to the CUSO Regulation - Comments due by March 29, 2021

The NCUA Board, at their January 2021 meeting, approved a proposed amendment to the CUSO Rule that would accomplish two important things:
1.  Expansion of authorized CUSO powers to include all types of loans a federal credit union may originate
2. Granting the NCUA Board additional flexibility to approve permissible activities and services

The NCUA is also seeking comment on broadening FCU investment authority in CUSOs. Comments must be received by March 29, 2021, as the proposed rule change was published in the Federal Register this morning, with a 30-day comment period. 
 
We encourage you to submit written comments in support of the NCUA Board proposal, identified by RIN 3133-AE95 by any of the following methods (select one only):

  • Federal eRulemaking Portalhttp://www.regulations.gov  Follow the instructions for submitting comments
  • FAX: (703) 518-6319 Include “[Your Name} – Comments on Proposed Rule: Credit Union Service Organizations (CUSOs)” in the transmittal.
  • Mail: Address to Melane Conyers-Ausbrooks, Secretary of the Board, National Credit Union Administration, 1775 Duke Street, Alexandria, VA 22314-3428
  • Hand Delivery/Courier: Same as mail address.
 
We feel it is helpful to send copies to each of the NCUA Board members, as they only see a synopsis of the comment letters, so they can see your individual comments.  You can email them to:


We have included links to copies of the following to assist you in preparing your own comment letters (feel free to shorten, edit or add to this draft as needed):

 
NACUSO appreciates the NCUA Board’s proposed expansion of CUSO powers to allow CUSOs to assist credit unions with auto lending and personal loans. As the marketplace has evolved, the competition for these types of loans has increased, making it more difficult for credit unions to maintain their market share in these important core lending areas. Allowing credit unions to collaborate and utilize industry owned CUSOs to help them achieve scale, while sharing costs and risk mitigation, will enable credit unions to offer competitive solutions to their members.
 
CUSOs have been used successfully by credit unions to offer credit cards, mortgages, member business loans and student loans. This regulation will extend the benefits of collaboration to the core lending areas of auto and personal lending.
 
CUSOs act as intermediaries to source loans for credit unions, helping credit unions to serve their members conveniently and efficiently, in today’s interconnected online world. With new FinTech competitors capturing market share with new tech solutions, having the opportunity to collaboratively build competitive high-tech solutions to better serve their members, is a real competitive advantage for credit unions.
 
NCUA already has CUSO oversight in place, through their CUSO Registry, CUSO Reviews and the ability to look at CUSOs through their credit union owners. This expansion of CUSO powers will have the same strong oversight that both the NCUA and state regulators have been utilizing in overseeing CUSOs over the past several years, ensuring safety and soundness remains a top priority.
 
Should you have any questions, or if NACUSO can assist you in sending in supportive comment letters on the NCUA’s proposed amendment to the CUSO Rule, please do not hesitate to contact Brian Lauer or Jack Antonini.