NAFCU Journal November December 2021

22 THE NAFCU JOURNAL November–December 2021 comments—based on feedback from members and staff knowledge—on pro- posed rules, it is important that agencies hear from individual credit unions as well.” Commenting on a proposed rule does require careful attention to notices of proposed rules, but the comment period is long enough to allow a credit union to review the proposal, evaluate how it will affect the organization or its members, and identify unintended consequences, burdensome requirements, significant costs or negative impact on members, said Schlehuber. “This process can be disrup- tive for smaller organizations with fewer resources, but it can also help you better prepare for new regulations,” she said. For example, when the NCUA approved the rule to transition federally-insured credit unions to the current expected credit loss (CECL) methodology, Ele- ments Financial had already put a lot of hours into planning to push the new accounting methodology out. Schlehuber explained, “The phase-in for the rule has been pushed out to 2022 due to the pan- demic, but we have a solid plan and will tweak as necessary as more is learned about the rule.” In addition, NAFCU members with assets approaching or already over $10 billion can participate in two NAFCU-sponsored summits each year that provide direct access to a supervisory representative from the NCUA to answer questions and provide instructive information. “We are hoping to offer the Large Credit Union Summit and other channels for direct conversations at our CEO Confer- ence in the spring and the Congressional Caucus each fall,” said Kossachev. “For smaller credit unions, we provide webi- nars to discuss specific issues or rules and answer questions.” Because some credit unions may want to preserve their anonymity when asking NCUA about specific requirements, NAFCU staff also have conversations with the regulator on the credit union’s behalf, she said. Although the previous White House administration was attempting to clarify and finalize a number of regulatory practices, some of those efforts were rescinded with the arrival of a new administration, said Kossachev. “Credit unions will continue to face challenges, but they must be vigilant,” she said. “Don’t be afraid to ask for more infor- mation and explanations and highlight inconsistencies or concerns. Reach out to NAFCU, that is why we are here.” Protecting consumers is a fabulous goal, but having multiple regulators approach it from different perspectives just muddies the waters and makes it difficult for credit unions to understand what constitutes compliance. LISA SCHLEHUBER, CEO, ELEMENTS FINANCIAL