NCUA Proposes Rule Changes to Ease Compliance Burden

January 20, 2026—The NCUA announced three sets of proposed regulatory changes designed to ease compliance demand without compromising the safety, soundness, or resilience of credit unions nationwide. These proposed changes signal the agency’s continued focus on modernizing outdated requirements that may no longer reflect current operational realities or risk profiles. Credit unions are encouraged to review these proposals in full in the Federal Register and submit their comments on the proposals.

Background

NCUA’s Deregulation Project is a multi-year initiative to review and revise regulations documented in Title 12, Chapter VII of the Code of Federal Regulations to ensure all align with agency’s mission, scope, and responsibility. This review follows Executive Order 14192, Unleashing Prosperity Through Deregulation.  

NCUA proposes changing or removing regulations that are obsolete, duplicative of statutory requirements, overly burdensome, or intended to serve as guidance, not as requirements. The Deregulation Project asserts that these changes would allow for more service innovation, reallocation of resources, greater compliance efficiency, and greater transparency in supervision and examination—all to the benefit of credit union members. Twelve proposed changes, two of which share a bullet in the summary list below, are currently in their comment phase. It is worth noting that while many of these proposals streamline the regulatory code, they do not, in all cases, eliminate all statutory requirements related to these issues.

Proposed Regulatory Changes

Comments are due on February 9, 2026, for the following proposals:

1. The Corporate Credit Union Regulation proposal recommending amendments to the eligibility requirements for a corporate credit union’s ALCO membership (12 CFT 704.8) and to its annual report and independent report filing requirements (12 CFR 704.15).
2. The change to 12 CFR 715, Changes for Supervisory Committee Audits and Verifications recommending edits to the language of the regulations governing supervisory committee audits and to the audit processes themselves to eliminate unnecessary, redundant, and overly prescriptive provisions and requirements.
3. The update to 12 CFR 748, Appendix A, Guidelines for Safeguarding Member Information which would reclassify these guidelines, which are currently not independently enforceable as statutory obligations, as guidance and reissue them as a Letter to Credit Unions.
4. The 12 CFR 748, Appendix B, Guidance on Response Programs for Unauthorized Access to Member Information and Member Notice proposal which considers this information supplementary guidance.

Comments are due on February 27, 2026, for these proposed changes:

• The Surety and Guarantor Requirements change proposing the removal of the segregated deposit or collateral requirements when and FICU acts as surety and guarantor to allow for greater flexibility in the design of lending products.  
• New proposed Limits on Loans to Other Credit Unions would eliminate the regulatory requirement for a federally insured credit union’s board to approve loans to other credit unions and adopt written policies setting internal limits for those loans.
• The Catastrophic Act Reporting proposal extending the reporting deadline to 15 calendar days, requiring notice to NCUA (rather than the regional director), and replacing the prescriptive recordkeeping list with a requirement to prepare a record of the event’s basic facts.
• The Accuracy of Advertising and Notice of Insured Status proposal changes how information about insurance coverage is provided to credit union members and the wider public by modifying language and display requirements.

Comments are due on March 16, 2026, for this third round of proposed regulatory changes:

• Two separate proposals to remove both Interpretive Ruling and Policy Statement 08-2 (IRPS 08-2) and 10-1 (IRPS 10-1) which repeat rules already covered by the Federal Credi Union Act and in the Chartering and Field of Membership Manual
• A proposal to similarly eliminate Interpretive Ruling and Policy Statement 11-02 (IRPS 11—02), the text of which is already covered in the Federal Corporate Credit Union Chartering Manual.
• Removal of 12 CFR 701.31 which the Board feels is an outdated nondiscrimination in lending regulation as it may not reflect current case law or regulatory developments under the Fair Housing Act.

As the comment periods deadlines draw near, count on EasCorp to keep you informed on our blog. For full details on these NCUA proposals and links to the Federal Register for each, please visit NCUA’s website. Please contact us with any questions.

This information is provided for educational purposes only. Please consult your legal counsel and compliance teams for additional information.