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MCUA Comments on NCUA Home-Based Credit Union Proposal

The Missouri Credit Union Association filed a comment letter with the National Credit Union Administration (NCUA) on Thursday, January 23, detailing concerns with NCUA’s proposed home-based credit union rule. The provisions in the proposal require that credit unions operate out of nonresidential office space, which will make it difficult for many home-based credit unions to continue operations. The following concerns were detailed in the comment letter:

  • Rules should not be issued to address singular or isolated problems;
  • The proposal is not justified on safety and soundness grounds;
  • The proposal ignores credit unions' unique history;
  • The harm to home-based credit unions could be irreparable because many will not have the resources to obtain office space;
  • The proposal was overly influenced by examiner convenience; and
  • NCUA’s records preservation rule already addresses records preservation concerns for all credit unions.

MCUA will continue to communicate these concerns with the agency. NCUA has not indicated when a final rule will be approved. 

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