NCUA Issues First Round of Deregulatory Actions

Posted by John Trull on December 11, 2025

Yesterday, the NCUA issued the first round of what we anticipate will be a number of deregulatory actions to remove prescriptive requirements and allow credit unions greater operational flexibility. This is a critical opportunity to work with our national partners to influence and support this effort.

What the Changes Mean

These initial actions – should they be finalized – will provide real world benefits to credit unions in general, but provide an outsized positive impact on smaller credit unions by eliminating exam requirements that have no impact on the safety and soundness of the credit union.

As an example, an auditor engagement letter under 12 CFR 715.10(a) requires that the engagement letter be signed by both the Supervisory Committee and the Auditor. There is nothing in statute that requires this and a credit union could be written up for a finding for being out of compliance with this guidance.

In another example, by removing the Appendix to part 748 regarding safeguarding member information, it removes guidance from rule. While this Appendix will still be published by NCUA, they would no longer result in exam findings other than in areas that are required by law.

More to Come in 2026

GoWest has focused NCUA advocacy efforts on ensuring that the NCUA’s framework is more transparent, predictable, and aligned with statute, so these initial actions and potential future actions represent positive progress that we will continue to build on in 2026.

Our goal for 2026 is to work with the NCUA to remove guidance embedded in rules, specifically:

• Subjective expectations not supported by statute
• Remove from regulations nonbinding guidance
• Push the NCUA to limit the use of legal opinion letters as a regulatory tool.

Our second priority is to work with the NCUA to improve the examination experience. Strengthening exam consistency and reducing unnecessary burden remain central themes. We are advocating for:

• Greater attention to exam scope discipline
• Reliable timelines and reduced duplication of requests
• Structural and operational improvements.

Just last week we met with the NCUA Western Region leadership team to discuss alignment between NCUA’s Central Office and the Region on support for these goals. We will continue to meet with NCUA leadership to provide input and guidance from credit unions in the GoWest region.

Get Involved

While the team at the NCUA has been identifying deregulatory opportunities, they are open to additional suggestions. If you have examples of rules that are not tied to statute and would not pose a material risk of loss to the Share Insurance Fund if changed, then please reach out to John Trull ([email protected]) to add your ideas for consideration.

GoWest will continue to engage with the NCUA on these efforts in 2026 and push for additional deregulation, so please continue to work with our team on making regulations work better for you and your members. Your participation in our advocacy helps make NCUA rules work better for your credit union and the credit union movement as a whole.

Posted in Advocacy on the Move, Regulatory Advocacy.