# PUBLIC COMMENT ON PROPOSED REGULATIONS: Chartering and Field of Membership for Federal Credit Unions-Interpretive Rulings and Policy Statements

**Submitted by the Center for Federal Accountability (CFA)**  
**Document Number:** 2026-02765

## 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 28 (Wednesday, February 11, 2026) [Federal Register Volume 91, Number 28 (Wednesday, February 11, 2026)] [Proposed Rules] [Pages 6138-6141] From the Federal Register Online via the Government Publishing Office [ www.gpo.gov ] [FR Doc No: 2026-02765] ======================================================================= ----------------------------------------------------------------------- NATIONAL CREDIT UNION ADMINISTRATION 12 CFR Part 701 RIN 3133-AF78 Chartering and Field of Membership for Federal Credit Unions-- Interpretive Rulings and Policy Statements AGENCY: National Credit Union Administration (NCUA). ACTION: Proposed rule. ----------------------------------------------------------------------- SUMMARY: The NCUA Board proposes to rescind its Interpretative Ruling and Policy Statement 06-1 (IRPS 06-1). Rescinding IRPS 06-1 would ease the compliance burden on Federal credit unions (FCUs) by limiting the number of sources that FCUs must check to ensure compliance with applicable chartering and field of membership (FOM) requirements. DATES: Comments must be received on or before April 13, 2026. ADDRESSES: Comments may be submitted in one of the following ways. (Please send comments by one method only): Federal eRulemaking Portal: https://www.regulations.gov/ . The docket number for the proposed IRPS recission is NCUA-2026-0265. Follow the ``Submit a comment'' instructions. If you are reading this document on [[Page 6139]] federalregister.gov , you may use the green ``SUBMIT A PUBLIC COMMENT'' button beneath this rulemaking's title to submit a comment to the regulations.gov docket. A plain language summary of the proposed recission is also available on the docket website. Mail: Address to Melane Conyers-Ausbrooks, Secretary of the Board, National Credit Union Administration, 1775 Duke Street, Alexandria, Virginia 22314-3428. Hand Delivery/Courier: Same as mailing address. Mailed and hand-delivered comments must be received by the close of the comment period. Public inspection: Please follow the search instructions on https://www.regulations.gov to view the public comments. Do not include any personally identifiable…

## 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 2026-03-23T21:00:27.187735+00:00._