Agree strongly	Agree somewhat	Disagree somewhat	Disagree strongly
The proposal would eliminate the entire charitable contributions rule (§ 701.25) so that any FCU can make donations without the prior approval of its board of directors and without regulatory restrictions as to recipients. (Currently, RegFlex FCUs are exempt from the entire charitable contributions rule).
The proposal would increase the nonmember deposit limit (§ 701.32(b)) from $1.5 million to $3 million.
NCUA acknowledges that, by eliminating RegFlex, RegFlex FCUs would lose their blanket exemption from the nonmember deposit cap. “From its review of the nonmember deposits presently held by RegFlex FCUs, however, the [NCUA] Board believes the proposal provides all of the necessary flexibility and regulatory relief to all FCUs without adversely affecting any of the RegFlex FCUs that have accepted nonmember deposits in excess of the cap.” Indicate the extent to which you agree or disagree with this statement.
The proposal would amend the fixed assets rule to extend the three-year time period to six years for any FCU that is acquiring unimproved land (the extension would not apply to any other kind of premises).
The proposal would generally prohibit FCUs from purchasing zero-coupon investments with maturities that exceed 10 years, except for FCUs that meet the “well capitalized standard,” which would be permitted to purchase zero-coupon investments with a maturity of up to 30 years.
The proposal would permit FCUs meeting the “well capitalized standard” to buy loans from other federally insured credit unions without regard to whether the loans are eligible obligations of the purchasing FCU’s members or the members of a liquidating credit union.
To meet the “well capitalized standard,” an FCU must have received a composite CAMEL rating of 1 or 2 during its last two exams and (1) maintained a “well capitalized” net worth classification for the immediately preceding six quarters, or (2) remained “well capitalized” for the immediately preceding six quarters after applying the applicable risk based net worth requirement.
The proposal would permit borrowing repurchase transactions in the following possible scenarios: (1) the borrowing and corresponding investment transactions must have matched maturities; (2) the matched maturity requirement would not apply if an FCU buys investments that mature no more than 30 days later than the borrowing repurchase transaction and the value of those investments does not exceed 100% of the FCU’s net worth; and (3) an FCU that meets the “well capitalized standard” may enter borrowing repurchase transactions with mismatched maturities greater than 30 days if the value of the investments does not exceed 100% of the FCU’s net worth.

Credit union
League

Less than $10 million
$10 million to $50 million
$50 million to $100 million
$100 million to $250 million
$250 million to $500 million
$500 million to $1 billion
$1 billion or more