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
Related Federal Register Documents
2026-16022, Corporate Credit Unions
The NCUA Board (Board) is issuing this action to rescind its Interpretive Ruling and Policy Statement (IRPS) 11-02, which addresses chartering corporate credit unions, because it is redundant to the Federal Corporate Credit Union Chartering Manual. This action eliminates potential confusion.
2026-16031, Chartering and Field of Membership for Federal Credit Unions-Interpretive Ruling and Policy Statement 08-2
The NCUA is saying goodbye to an old rule called IRPS 08-2 because its key points are now part of the main Chartering Manual. This change makes life easier for federal credit unions by cutting down on the paperwork and checks they need to do. The new rule kicks in on September 8, 2026, helping credit unions serve their communities faster without extra hassle.
2026-16027, Suretyship and Guaranty; Segregated Deposit and Collateral
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2026-16029, Third-Party Servicing of Indirect Vehicle Loans
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2026-16030, Purchase, Sale, and Pledge Of Eligible Obligations
The National Credit Union Administration is making it easier for federal credit unions to handle buying, selling, and pledging loans by cutting out strict rules on what their policies must include. This change lets credit unions be more flexible and efficient while still following important conflict-of-interest rules already in place. The new rule kicks in on September 8, 2026, helping credit unions save time without changing how they protect members' money.
2026-16024, Chartering and Field of Membership for Federal Credit Unions-Interpretive Ruling and Policy Statement 10-1
The NCUA Board (Board) is rescinding Interpretive Ruling and Policy Statement (IRPS) 10-1. The Chartering and Field of Membership Manual (Chartering Manual) incorporates NCUA's current chartering requirements for federal credit unions (FCUs), making IRPS 10-1 unnecessary. This rescission reduces the burden for FCUs by limiting the number of sources that they must check to verify compliance with applicable requirements. After considering the public comments, the Board adopts the proposal without modification.
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