The National Credit Union Administration (NCUA) has announced two additional rounds of proposed regulatory changes under its Deregulation Project. The proposals address fidelity bond coverage, incidental powers, Central Liquidity Facility requirements, investment reserves, charter conversions, and share insurance disclosures.
If adopted, the changes could reduce administrative burdens and provide greater flexibility. The proposals are not final, so credit unions should continue following existing requirements while monitoring developments.
Round 12: Bond Coverage, Incidental Powers, and Liquidity
Announced October 14, 2026, the twelfth round includes three proposals. Review the NCUA’s Round 12 announcement and proposed changes.
- Fidelity bond coverage: Proposed revisions would simplify certain purchase and renewal requirements, approved bond form procedures, and guidance on coverage levels. Credit unions should continue maintaining adequate coverage and may wish to review their current coverage and renewal processes.
- Incidental powers: Federal credit unions (FCUs) could apply directly to the NCUA Board for approval of activities not already recognized as authorized incidental powers, without first obtaining an advisory opinion from the Office of General Counsel. FCUs considering new activities may wish to review the proposed process.
- Central Liquidity Facility (CLF): Proposed changes would simplify certain membership and reporting requirements, incorporate some pandemic-era changes, and provide more flexibility for capital stock subscription adjustments. Credit unions that participate in or may rely upon the CLF should assess whether the proposed changes could affect their liquidity planning or administrative processes.
The comment period closes December 14, 2026.
Round 13: Investment Reserves, Charter Conversions, and Share Insurance Notices
Announced October 20, 2026, the thirteenth round also includes three proposals. Review the NCUA’s Round 13 announcement and proposed changes
- Nonconforming investment reserves: The NCUA proposes eliminating the special reserve requirement for certain nonconforming investments held by federally insured, state-chartered credit unions. These credit unions should review the proposal to determine whether it could affect their investment accounting or reserve practices.
- Conversion to a state charter: The NCUA proposes removing a regulation addressing continued federal share insurance following an FCU’s conversion to a state charter because the agency considers the provision outdated and duplicative. Credit unions contemplating a charter conversion should review the proposal alongside applicable chartering guidance.
- Share insurance disclosures: Federally insured credit unions would retain the obligation to notify members about share insurance coverage but would have greater flexibility in how they provide the information, including alternatives to certain hard-copy materials. Credit unions should monitor this proposal before changing existing disclosure practices.
The comment period closes December 21, 2026.
Credit unions do not need to implement changes based on these proposals. However, they can review the provisions relevant to their operations, identify potential cost or process savings, and determine whether to submit comments before the applicable deadlines. Credit unions should also monitor the rulemaking process for final rules and effective dates.

