The MD|DC Credit Union Association recently submitted two comment letters to the NCUA as part of its Deregulation Project. The letters support regulatory efforts to refine the balance between necessary oversight and operational flexibility that benefits credit unions and the members they serve.

Guidelines for Safeguarding Member Information

The Association supports the NCUA’s plan to remove Appendix A from part 748, guidelines for safeguarding member information from the Code of Federal Regulations (CFR) and turn it into guidance instead of a strict rule. Appendix A explains how credit unions should protect member information. But since it’s not an actual regulation, keeping it in the CFR may cause confusion.

By removing Appendix A from the CFR and publishing its content as a Letter to Credit Unions, it would make expectations clearer, easier to update, and better aligned with today’s data security and privacy needs. It keeps strong consumer protections in place while reducing unnecessary complexity.

Supervisory Committee Audits & Verification (Part 715)

The Association also commented on the NCUA’s proposal to modernize and streamline Part 715 governing supervisory committee audits for federal insured credit unions. The Association agreed with removing outdated language, reducing repetitive requirements, and making audit paperwork easier by eliminating duplicate obligations. It also supported aligning Part 715 with modern auditing standards to reduce confusion and keep guidance consistent with current professional practices.