CUNA Comment Call: NCUA Proposed Definition of a "Small Entity"
The National Credit Union Administration (NCUA) has issued a proposed rule and proposed Interpretive Ruling and Policy Statement (IRPS) 12-2 that would amend existing IRPS 87–2 that defines a "small entity," as amended by IRPS 03–2, and also amend two NCUA regulations that apply asset thresholds.
Specifically, the proposal would amend NCUA‘s definition of a "small entity," by increasing the asset threshold from $10 million to $30 million. The agency would revisit this threshold at least every three years.
The proposed asset threshold of $30 million would also provide regulatory compliance relief for smaller credit unions under two regulations that reference the current "small entity" asset threshold of $10 million. Currently, the $10 million asset threshold is used to define a "complex" credit union for determining whether risk-based net worth requirements apply. In addition, credit unions with an asset range of $10 to $50 million would be subject to certain requirements under the interest rate risk final rule that was effective on September 30, 2012.
Please submit your comments to CUNA by October 23, 2012.
Click here for CUNA's Regulatory Comment Call on this proposal, and contact Dennis Tsang with any comments or questions.
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