DCUC Submits Comments to NCUA, Regulatory Clarity and Reduced Compliance Burdens

WASHINGTON, DC – The Defense Credit Union Council (DCUC) today submitted four comment letters to the National Credit Union Administration (NCUA) addressing several proposed rulemakings and policy changes aimed at streamlining regulations and improving clarity for federal credit unions. ​

Across the letters, DCUC shared how credit unions continue to commit their institutions to prioritizing fairness, responsible lending, and nondiscriminatory access as part of their financial services. DCUC expressed support for efforts that simplify regulatory frameworks while maintaining strong consumer protections. 
 
Nondiscrimination Requirements 
In comments on the NCUA’s proposed rule on Nondiscrimination Requirements (NCUA-2026-0034), DCUC supported the agency’s proposal to remove regulatory language that summarizes provisions of the Fair Housing Act (FHA) related to discrimination in real estate lending, appraisals, and advertising. 
 
DCUC noted that these protections are already established under the FHA, the Equal Credit Opportunity Act (ECOA), and Regulation B, making duplicative provisions within NCUA regulations unnecessary. 
 
“Credit unions have long demonstrated a strong commitment to responsible lending and nondiscriminatory access to credit,” DCUC wrote. “Eliminating duplicative provisions will help simplify the regulatory framework for credit unions while preserving all applicable consumer protections.” 
 
DCUC also supported the NCUA’s proposal to rescind Section 701.31 in its entirety, including requirements related to providing appraisals for subordinate liens on dwellings. DCUC agreed with the NCUA that while these are sound business practices, maintaining them as regulatory mandates is unnecessary. Additionally, DCUC supported removing Section 701.31(d), noting that compliance with the Department of Housing and Urban Development’s FHA regulations is sufficient to ensure adherence to federal nondiscrimination standards. 
 
Chartering and Field of Membership Policies 
DCUC also submitted comment letters on the NCUA’s proposals to rescind Interpretive Ruling and Policy Statement (IRPS) 10-1 and IRPS 08-2, both related to chartering and field-of-membership requirements for federal credit unions. 
 
DCUC supports consolidating guidance within the NCUA’s Chartering and Field of Membership Manual, stating that reducing the number of regulatory sources credit unions must consult will improve regulatory clarity and efficiency. 
 
“Consolidating interpretive guidance within the NCUA’s Chartering and Field of Membership Manual will make it easier for credit unions to identify and understand the agency’s supervisory expectations,” DCUC noted. 
 
However, DCUC emphasized that its support for rescinding these policy statements is contingent on maintaining transparency and accessibility in the manual. DCUC urged the NCUA to ensure the manual remains readily available on the agency’s public website, clearly mark and date updates, and provide notice and an opportunity for public comment before implementing substantive changes. 
 
These steps, DCUC noted, will ensure credit unions receive adequate notice of potential policy changes and have the opportunity to provide feedback before new guidance is implemented. 
 
DCUC concluded by expressing appreciation for the NCUA Board’s efforts to streamline and modernize its regulatory framework and encouraged the agency to continue engaging with credit unions through listening sessions and outreach to identify additional opportunities to improve regulatory clarity and reduce unnecessary compliance burdens. ​