Credit Unions Freed from Outdated Borrowing Caps
Published Date: 1/28/2026
Proposed Rule
Summary
The NCUA wants to remove a rule that limits how much federally insured credit unions can borrow because it’s already covered by law. This change affects all federally insured credit unions and will cut down on confusing rules, especially for state-chartered ones. Comments on this proposal are open until March 30, 2026, so now’s the time to weigh in!
Analyzed Economic Effects
3 provisions identified: 3 benefits, 0 costs, 0 mixed.
Duplicate 50% Borrowing Rule Removed
The NCUA proposes removing a regulation that limits borrowing to 50 percent of paid-in and unimpaired capital and surplus because that 50% limit for federal credit unions is already set by statute and implemented in 12 CFR 701.38. The change would simplify the Code of Federal Regulations for federal credit unions without changing their statutory borrowing obligation.
State-Chartered Credit Union Flexibility
For federally insured, state-chartered credit unions (FISCUs), removing the rule would end a federal 50% borrowing limit and the related waiver process and would reduce federal regulatory burden and administrative requirements. The Board says safety and soundness for these FISCUs would continue to be monitored through risk-based examination and coordination with state regulators.
Small Credit Unions Not Significantly Impacted
The NCUA certifies that, to the extent the rule has any economic effects, they are deregulatory and the proposed removal would not have a significant economic impact on a substantial number of small credit unions. The NCUA defines small credit unions for this analysis as those having under $100 million in assets.
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