NCUA Proposes Ditching Collateral for Credit Union Guarantees
Published Date: 12/29/2025
Proposed Rule
Summary
The National Credit Union Administration wants to make it easier for federally insured credit unions to act as sureties and guarantors by removing the need for segregated deposits and collateral. This change gives credit unions more freedom to create products that better serve their members. Comments on this proposal are open until February 27, 2026, so now’s the time to weigh in!
Analyzed Economic Effects
2 provisions identified: 2 benefits, 0 costs, 0 mixed.
Remove Segregated Collateral Rules
The NCUA proposes to remove paragraphs (c)(3) and (d) of Sec. 701.20 so federally insured credit unions (FICUs) would no longer need segregated deposits or the current collateral rules (including the 100% collateral category for cash and certain U.S. obligations and the 110% category for real estate and marketable securities) when acting as a surety or guarantor. The agency says this change will give FICUs greater flexibility to design products, simplify the regulatory framework, and reduce compliance burdens.
Small Credit Unions Unlikely Affected
The NCUA certified under the Regulatory Flexibility Act that the proposed rule would not have a significant economic impact on a substantial number of small credit unions and defines small credit unions as those with under $100 million in assets. The agency also states it is unlikely that small credit unions will participate in suretyship or guaranty activities and therefore are unlikely to be significantly affected.
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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
The NCUA Board (Board) is amending its regulations to eliminate prescriptive segregated deposit and collateral requirements for suretyship and guaranty agreements. By removing these requirements, the Board is authorizing federally insured credit unions (FICUs) acting as sureties and guarantors to design products that address member needs while maintaining safety and soundness standards. Federal credit unions (FCUs), and federally insured, state-chartered credit unions (FISCUs) if permitted under state law to act as a surety or guarantor, continue to be subject to other requirements related to these arrangements, including the applicable lending regulations. The final rule follows publication of the December 29, 2025, proposed rule, and takes into consideration the public comments received.
2026-16029, Third-Party Servicing of Indirect Vehicle Loans
The NCUA Board (Board) is issuing a final rule removing NCUA's unnecessarily prescriptive regulation regarding third-party servicing of indirect vehicle loans. This action will reduce regulatory burden and provide federally insured credit unions (FICUs) with greater operational flexibility, consistent with a principles-based supervisory approach. The intent is to reduce administrative costs and compliance complexity, enabling credit unions to serve their members more efficiently.
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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Federally insured credit unions (FICUs) will get more time to report catastrophic events to the National Credit Union Administration, and they won’t have to provide a long list of details anymore. This change helps credit unions focus on bouncing back quickly without extra paperwork. Comments on this proposed rule are open until February 27, 2026, so speak up if you have thoughts!
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