NCUA Proposes Removing Limits on Loans Between Credit Unions Nationwide
Published Date: 12/29/2025
Proposed Rule
Summary
The National Credit Union Administration (NCUA) wants to remove the rules that control how credit unions can lend money to other credit unions. This change won’t affect the basic laws that still apply, but it means fewer official rules to follow. Credit unions and their members should know this update is open for comments until February 27, 2026, so now’s the time to speak up!
Analyzed Economic Effects
4 provisions identified: 3 benefits, 1 costs, 0 mixed.
Paperwork burden reduced by 1,650 hours
The proposed rescission would remove the information-collection requirements in 12 CFR 701.25(b) tied to OMB Control Number 3133-0207 (expiration October 31, 2025) and NCUA estimates this will reduce public information-collection burden by an estimated 1,650 annual burden hours. Upon finalization, NCUA will ask OMB to revise the control number to reflect the change.
Existing loan limits and eligibility remain
The proposal removes only the board-approval/policy documentation requirement; the other substantive parts of 12 CFR 701.25 remain in force, including the aggregate limit on loans to other credit unions of 25 percent of the lending FCU's paid-in and unimpaired capital and surplus and limits on loans to a single credit union borrower. The rule also preserves the eligibility and aggregate limits related to investments in subordinated debt and makes the 701.25 requirements applicable to FISCUs through 12 CFR 741.227.
Boards no longer must adopt loan policies
If you run or sit on the board of a federally insured credit union (FICU), the NCUA proposes to remove 12 CFR 701.25(b), which currently requires boards to approve all loans to other credit unions and adopt written policies setting aggregate and single-borrower limits. Federal Credit Unions would still be subject to the statutory board-approval requirement, and federally insured state-chartered credit unions (FISCUs) would look to state law or other applicable rules for any board-approval requirements.
NCUA says small credit unions not significantly harmed
The NCUA treats small credit unions as those with under $100 million in assets and certifies that the proposed removal of 12 CFR 701.25(b) would not have a significant economic impact on a substantial number of small credit unions. The agency reached this conclusion while conducting the Regulatory Flexibility Act analysis for the proposal.
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Key Dates
Department and Agencies
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