Credit Union Watchdog Admits Its Own Rules Are Too Confusing
Published Date: 12/11/2025
Proposed Rule
Summary
The National Credit Union Administration (NCUA) is moving its member information protection guidelines out of the official rulebook and into a more flexible letter format. This change affects federally insured credit unions, making it easier for them to stay updated and follow the rules without confusion. Comments on this change are open until February 9, 2026, with no new costs involved—just smoother, clearer guidance!
Analyzed Economic Effects
4 provisions identified: 3 benefits, 0 costs, 1 mixed.
Formal Notice and Triennial Review May Change
The Board notes that keeping Appendix A in the CFR had ensured a roughly three-year regulatory review and that changes were typically published in the Federal Register with an opportunity for public notice and comment; moving the guidance to Letters may reduce that automatic publication/review process. The Board is soliciting comments on this proposed change through February 9, 2026.
Guidance Moved Out of CFR
The NCUA proposes to remove Appendix A to 12 CFR part 748 and publish its content as a Letter to Credit Unions so federally insured credit unions can receive the same guidance in a more flexible, easier-to-update format. The proposal is open for comment until February 9, 2026.
No New Paperwork Required
The NCUA states the proposed change does not create any new information-collection requirements under the Paperwork Reduction Act, so affected entities are not being required to complete new reporting or recordkeeping because of this proposal.
Small Credit Unions Face No Significant Cost
The NCUA certifies under the Regulatory Flexibility Act that the proposed removal of Appendix A will not have a significant economic impact on a substantial number of small credit unions; the agency defines small credit unions as those with under $100 million in assets.
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Key Dates
Department and Agencies
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Previous: 2025-22488 — Supervisory Committee Audits and Verifications
The National Credit Union Administration (NCUA) wants to make audits easier and less annoying for credit unions by cutting out old, extra rules that don’t add value. This means credit unions get more freedom to operate while still keeping audits trustworthy. If you’re involved with a credit union, get ready to share your thoughts by February 9, 2026!
Next: 2025-22490 — Guidance on Response Programs for Unauthorized Access to Member Information and Member Notice
The National Credit Union Administration (NCUA) is updating how it shares rules about handling unauthorized access to member info. Instead of keeping detailed guidance in the official rulebook, they’ll publish it separately to make updates easier and reduce confusion for credit unions. This change affects federally insured credit unions and invites public comments until February 9, 2026, with no new costs involved.
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