CUNA Comment Letter

NCUA Strategic Plan for 2003-2008

July 12, 2002

Mr. James Patrick
Director of Strategic Planning
National Credit Union Administration
Office of Strategic Program Support and Planning
1775 Duke Street
Alexandria VA 22314

Dear Mr. Patrick:

The Credit Union National Association is pleased to comment on the agency’s proposed Strategic Plan for 2003-2008. CUNA represents over 90% of our nation's more than 10,500 state and federal credit unions. The comments in this letter were developed under the auspices of CUNA’s Examination and Supervision Subcommittee, chaired by South Carolina Credit Union League President John Franklin. CUNA’s Examination and Supervision Subcommittee looks forward to meeting with you in July to discuss the agency’s plans and our views on it. In the meantime, there are several key points we would like to emphasize regarding the plan.

Summary of CUNA’s Views

NCUA Plan Is a Useful Resource for Credit Unions

Under the Government Performance and Results Act, the National Credit Union Administration and other federal regulatory agencies are required to develop a strategic plan, as well as an annual performance plan that explains how the agency will implement its strategic goals.

In general, we found NCUA’s Strategic Plan 2003-2008 to be useful and an important resource that will enable the credit union system to understand more thoroughly the agency’s priorities, the steps its plans to take to implement its goals, and its allocation of resources. We also think that the five strategic goals that the agency has identified -- financial health of the credit union system; safe integration of technology; flexible regulatory environment; credit union growth and empowerment; and efficiency at the agency – are critical to the success of the agency as well as to the entire credit union network and thus, are appropriate goals on which to focus agency resources.

We do have some recommendations that we believe will clarify the agency’s intent, thus making a good product even better.

The Plan Reflects a Proactive Approach for NCUA Beyond Safety and Soundness

In several areas, the plan reveals the agency's intent to develop programs and initiatives that we believe are beyond its purview as a regulatory agency. While many of the goals and ideals addressed in the plan are laudable, we do not believe it is NCUA's role to undertake them. Because of the unique relationship of NCUA as a credit union regulator, the agency should confine its involvement to safety and soundness, empowering credit unions, and expanding earned regulatory flexibility as opposed to any activity involving the establishment of credit union priorities.

Examples of goals that illustrate this point are:

CUNA believes that in NCUA’s proper role as a regulator of safety and soundness, the agency should focus on and limit its guidance to risk-related issues.

The Plan Should Incorporate the Agency’s Crisis Management Planning Efforts

Since September 11, 2001, the entire nation has become much more aware of security and safety issues in the workplace, as well as in other environments. Like other agencies, NCUA has developed and made use of resources that will help it address crisis situations on a broad scale both within the agency as well as throughout the credit union system, should such events occur. We believe it would be highly useful for the agency and for credit unions if the Strategic Plan incorporated NCUA’s crisis management goals and objectives, and addressed the resources that would be diverted to deal with such events.

Specific Goals and Strategies for Risk-Focused Examinations Should Be Included

Beginning in September 2002, NCUA will initiate a risk-focused process to examine federal credit unions. The risk-focused examination (RFE) process is an approach designed to allocate agency resources to the credit unions and areas exhibiting weaknesses or adverse trends. Examiners will evaluate both credit union performance and management’s ability to identify, measure, monitor, and control risk. State regulators will also be utilizing this RFE process.

The Strategic Plan does reference the RFE process under Strategic Goal #1 and in other provisions in the plan. However, because this initiative will have such a significant impact on credit unions, we believe it is important for NCUA to include its specific goals and the strategies it intends to implement with regard to risk-focused exams.

Language in the Human Capital Management Plan Should Be Clarified

While it would seem evident that NCUA’s goals and strategies in the area of management and human capital are intended to apply only to the agency itself, the language in the Strategic Plan is not always clear on this point. CUNA feels strongly that NCUA should not be involved in individual credit union management and human capital issues unless they were truly safety and soundness issues. Therefore, CUNA recommends that the language in the plan be clarified to indicate that the goals and strategies in the Appendix pertain solely to human capital issues at NCUA and not to individual credit unions.

The Plan Should Incorporate Specific Goals and Objectives for Expanding the Reg-Flex Program for Federal Credit Unions

CUNA continues to maintain that one of the most important regulations adopted for federal credit unions in recent times is the Reg-Flex rule initiated by Chairman Dennis Dollar. The rule and its potential for even more flexibility for federal credit unions signaled a real desire on the part of the agency to support innovations at federal credit unions that are well-managed. We urge the agency to include greater details in its objectives, for example under Strategic Goal #3 regarding regulatory flexibility, to provide further direction to agency personnel as well as to federal credit unions regarding additional review and consideration of expanded Reg-Flex authority.

The Plan Should Address Issues for Federally-Insured State-Chartered Credit Unions

There is relatively little discussion in NCUA’s Strategic Plan regarding state-chartered federally-insured credit unions (FISCUs). Given the concerns in the credit union industry about bureaucracy, efficiency, and fairness with regard to FISCUs, CUNA suggests that NCUA modify its plan to further address this important issue.

Increased Agency Efficiency

We believe the Strategic Plan provides a number of goals and objectives to enhance the agency’s efficiency. However, we also believe there should be greater reporting to credit unions regarding the extent to which the agency is meeting those goals. For example, the agency has stated that the risk-focused examinations will provide for greater efficiency in the examination process and enable the agency to contain costs related to supervision. We urge NCUA to put in place a system for regularly reporting to credit unions on the extent to which those goals are being met and costs are held constant or reduced.

Conclusion

Thank you for the opportunity to provide our views on NCUA’s Strategic Plan for 2003-2008. We strongly believe that the plan is a key document that should present the agency’s appropriate role as a safety and soundness regulator, while affording credit unions the latitude they must have to make their own decisions and determine for themselves what activities are in the best interests of their members. We urge you to revise the plan as detailed above to reflect that vision. Please do not hesitate to contact me at (202) 508-6736 or at mdunn@cuna.com if you have any questions about our comments.

Sincerely,

Mary Mitchell Dunn
Associate General Counsel