# PUBLIC COMMENT ON PROPOSED REGULATIONS: Dependent Care and Board Member Expense Reimbursement

**Submitted by the Center for Federal Accountability (CFA)**  
**Document Number:** 2026-01382

## Executive Summary

The Center for Federal Accountability submits this draft comment to support timely public record participation while full model-backed legal analysis is queued. This draft identifies baseline accountability concerns and preserves key issues for agency consideration before the close of comments.

## Table of Authorities (to be finalized)

- Administrative Procedure Act (5 U.S.C. 551 et seq.)
- Agency enabling statute and implementing regulations (rule-specific citations to be finalized)

## Key Concerns

- The agency should clearly identify statutory authority for each material requirement in the proposal.
- The agency should provide transparent cost, burden, and implementation assumptions with reproducible methodology.
- The agency should address foreseeable operational risks and unintended consequences for regulated parties and the public.

## Preliminary Analysis

This preliminary draft is generated from the available Federal Register text excerpt below and is intended to preserve issues for the rulemaking record. A full model-backed CFA legal analysis can be substituted in a subsequent revision.

>  
 
 Federal Register, Volume 91 Issue 16 (Monday, January 26, 2026) 
 
  
[Federal Register Volume 91, Number 16 (Monday, January 26, 2026)]
[Proposed Rules]
[Pages 3073-3081]
From the Federal Register Online via the Government Publishing Office [ www.gpo.gov ]
[FR Doc No: 2026-01382]

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Proposed Rules
                                                Federal Register
________________________________________________________________________

This section of the FEDERAL REGISTER contains notices to the public of 
the proposed issuance of rules and regulations. The purpose of these 
notices is to give interested persons an opportunity to participate in 
the rule making prior to the adoption of the final rules.

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Federal Register / Vol. 91, No. 16 / Monday, January 26, 2026 / 
Proposed Rules

[[Page 3073]]

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NATIONAL CREDIT UNION ADMINISTRATION

12 CFR Part 701

RIN 3133-AF64

Dependent Care and Board Member Expense Reimbursement

AGENCY: National Credit Union Administration (NCUA).

ACTION: Proposed rule.

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SUMMARY: The NCUA Board proposes to amend its regulations concerning 
the reimbursement of reasonable expenses for federal credit union (FCU) 
officials. The proposed rule would enable FCU boards to establish 
policies that allow for the payment of reasonable dependent care costs 
incurred by volunteer officials while attending board meetings and 
performing their official duties. This proposed amendment would include 
dependent care costs as a reimbursable expense. The proposed changes 
aim to provide FCUs with greater flexibility to create family-friendly 
policies, thereby alleviating dependent care costs for volunteer 
officials, which may otherwise hinder their ability to volunteer.

DATES: Comments must be received by on or before…

## CFA Recommendations

1. Publish a clear crosswalk from each proposed requirement to its statutory basis.
2. Expand and disclose the quantitative assumptions used in cost-benefit analysis.
3. Provide implementation alternatives and phase-in options to reduce compliance risk.
4. Extend or reopen comment if substantial updates are made after publication.

## CFA Contact

Center for Federal Accountability (CFA)  
8401 Mayland Dr # 7387  
Richmond, VA 23294  
policy@federalaccountability.com | https://www.federalaccountability.com/

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_Generated via cursor provider fallback at 2026-03-23T10:42:44.248453+00:00._