The National Credit Union Administration (NCUA) is moving forward with a multi-phase Deregulation Project designed to review and modernize existing credit union regulations. The initiative focuses on identifying rules that may be outdated, duplicative, or unnecessarily burdensome—while continuing to emphasize safety and soundness.
Over the past several months, the NCUA has released multiple rounds of proposed regulatory changes and invited industry feedback through public comment periods. While not every proposal will affect every credit union, the overall direction is worth noting. Over time, these changes could reduce compliance effort in certain areas, clarify regulatory expectations, or eliminate requirements that no longer align with current operations.
Highlights from the Deregulation Project
To date, the NCUA has announced five rounds of proposed changes:
- Round 1 (December 2025): Focused on removing outdated governance and audit requirements, including changes to ALCO committee composition rules, streamlining supervisory committee audit provisions, and removing obsolete appendices related to member information security.
- Round 2 (December 2025): Addressed loan-related and reporting requirements, including proposed changes to surety and guarantor rules, elimination of duplicative requirements on loans to other credit unions, updates to catastrophic act reporting, and simplification of advertising and insured-status notices.
- Round 3 (January 2026): Targeted duplication and outdated guidance, including the proposed removal of the NCUA’s nondiscrimination rule that overlaps with other federal laws and rescission of certain interpretive rulings now addressed elsewhere.
- Round 4 (January 2026): Proposed additional reductions in regulatory complexity, such as removing written-plan requirements tied to public unit and nonmember shares, eliminating certain notification rules, and deferring borrowing authority limitations to applicable state law for state-chartered credit unions.
- Round 5 (February 2026): The most recent proposals focus on flexibility and clarity, including simplified requirements for conversions to mutual savings banks, streamlined notice requirements for mergers and insurance changes, and rescinding redundant field-of-membership guidance.
Why This Matters for Credit Union Leadership
For management teams and boards, the NCUA’s Deregulation Project presents an opportunity to stay informed and evaluate whether upcoming changes could meaningfully impact policies, procedures, governance practices, or examination focus. In some cases, proposed changes may reduce administrative burden; in others, they may shift how compliance responsibilities are documented or communicated.
Hawkins Ash continues to monitor these developments closely and can help credit unions assess how finalized changes may affect operations, audits, and regulatory compliance strategies.
NCUA Deregulation Project – Official Resources
For those who would like to review the original NCUA announcements and proposed rule changes in more detail, the following resources provide additional context and background:
- NCUA Announces Deregulation Project and First Round of Proposed Regulatory Changes | NCUA
- NCUA Announces Second Round of Deregulation Proposals | NCUA
- NCUA Announces Third Round of Deregulation Proposals | NCUA
- NCUA Announces Fourth Round of Deregulation Proposals | NCUA
- NCUA Announces Fifth Round of Deregulation Proposals | NCUA
