On Dec. 10, 2025, the National Credit Union Administration (NCUA) announced a Deregulation Project to review its regulations in hopes of revising and eliminating those deemed one of the following:

• Obsolete
• Duplicative of statutory requirements
• Intended to serve as guidance, not requirements
• Overly burdensome

NCUA’s first step in the project is issuing the following four separate proposals clarifying guidance or eliminating unduly burdensome or obsolete requirements: 

1. Changes for Corporate Credit Unions – 12 CFR 704.8 and 704.15: Amend its regulations for corporate credit unions by removing the requirement that a corporate credit union’s asset and liability management committee (ALCO) must have at least one member who is also a member of the corporate credit union’s board of directors.
2. Changes for Supervisory Committee Audits and Verifications – 12 CFR 715: Amend its regulations governing supervisory committee audits to eliminate unnecessary, redundant and overly prescriptive provisions.
3. Changes for Guidelines for Safeguarding Member Information – 12 CFR 748 Appendix A: Remove Appendix A to part 748, guidelines for safeguarding member information, from the Code of Federal Regulations.
4. Changes for Guidance on Response Programs for Unauthorized Access to Member Information and Member Notice – 12 CFR 748 Appendix B: Remove Appendix B to part 748, guidance on response programs for unauthorized access to member information and member notice, from the Code of Federal Regulations.

Expectations are that this is the first step in a wave of NCUA deregulation in 2026.

Doeren Mayhew’s compliance pros will continue to monitor changes and the impacts they will have on credit unions.