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MCUA Comment Letter on Charitable Donation Accounts Proposal

The National Credit Union Administration (NCUA) has posted the letters filed for comment on the charitable donation accounts proposed rule, which Credit Union National Association (CUNA), the National Credit Union Foundation (NCUF), and a number of leagues support in principle with a few improvements. Click here to see the Missouri Credit Union Association's (MCUA) comment letter. 

In all, 24 parties commented, including MCUA and 12 other leagues. Many of the letters discussed the way the 3% net worth limitation is calculated, arguing that the limitation should be calculated at the time of purchase or placement of the investment, instead of throughout the duration of the investment.

In addition, many noted that the proposal could be improved by allowing corporate credit unions to participate in the program by modifying part 704 of NCUA’s rules and regulations. The SEC oversight requirements of the program were discussed frequently, noting that the proposal as written may create redundant supervision for OCC-regulated trust companies that are also national banks. Interestingly, the American Bankers Association discussed this issue in detail, echoing concerns of CUNA, NCUF, and a number of leagues. Also, several commenters argued that the proposal should be modified to allow for recoupment of a credit union’s costs to administer the program, or that NCUA should use this as an opportunity to look at expanding credit union investment authority more broadly.

MCUA strongly supports the concepts of this proposal and looks forward to the opportunity to work with NCUA to improve it before the rule is finalized. Credit unions appreciate NCUA’s willingness to create this creative, novel structure to benefit charities and the credit union system, allowing credit unions to do well by doing good.