In a letter to the NCUA regarding its 2021 Regulatory Review with one-third of regulations, NAFCU Director of Regulatory Affairs Ann Kossachev wrote to NCUA’s General Counsel Frank Kressman. Kossachev noted that certain aspects of the regulations under review may require Congressional action to achieve full modernization with industry standards and practices. She urged the NCUA to work with members of Congress and support legislation to update the Federal Credit Union Act.
For instances where the NCUA has full authority to make changes, Kossachev outlined recommendations for the NCUA to consider. These recommendations include focusing on intent and usefulness of SARs rather than technical compliance, including clear instructions for credit unions on addressing AML/CFT priorities in their risk assessments, considerations for flexibility on post-employment benefit offers, and more.
In the letter, Kossachev also discusses the need to update procedures on record retention for credit unions. She urges the NCUA to align record retention requirements with statutes of limitations based on product and information type, provide guidance on corporate governance documents from merged credit unions, including whether they fall under the record requirements and if so the length of time the records should be retained.
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