Credit Unions Deregulated on Inter-Loans... But Caps Stay the Same
Published Date: 8/6/2026
Rule
Summary
Starting September 8, 2026, federal credit unions won’t have specific NCUA rules limiting loans to other credit unions, but they still must follow the main law caps. State-chartered credit unions insured by the feds keep following their own rules. This change simplifies the rules but doesn’t change how much money can be loaned overall.
Analyzed Economic Effects
4 provisions identified: 2 benefits, 2 costs, 0 mixed.
Statutory Loan Caps Still Apply
Even after September 8, 2026, federal credit unions remain subject to statutory loan limits: aggregate loans to other credit unions may not exceed 25 percent of the lending credit union's paid-in and unimpaired capital and surplus, and single-member aggregate borrowing is limited to 10 percent of unimpaired capital and surplus (12 U.S.C. provisions cited). The rule removal does not change those dollar or percentage caps.
Written Policy Requirement Removed
If you run a federally insured credit union, starting September 8, 2026 you will no longer be required by NCUA regulation to adopt written board approval policies for loans to other credit unions (12 CFR 701.25(b) is removed). You must still follow the underlying statutory requirement that your board approve loans to other credit unions.
State-Chartered FISCUs Still Follow State Law
If you are a federally insured, state‑chartered credit union (FISCU), you remain subject to any applicable NCUA or state law or regulation about loans to other credit unions and should consult state law to see if board approval or written policies are required. The federal rescission does not override state requirements.
Paperwork Burden Reduced by 1,250 Hours
The rescission of 12 CFR 701.25(b) reduces the public information collection burden by an estimated 1,250 annual burden hours under OMB Control Number 3133-0207. NCUA states this change is deregulatory and estimates reduced compliance time industry‑wide.
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Key Dates
Department and Agencies
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