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NCUA Chairman Todd M. Harper Statement on the Advance Notice of Proposed Rulemaking on Part 749, Records Preservation Program

April 2024
NCUA Chairman Todd M. Harper Statement on the Advance Notice of Proposed Rulemaking on Part 749, Records Preservation Program

As Prepared for Delivery on April 18, 2024

Thank you, Kelly, Matt, and Gira, for your briefing on this advance notice of proposed rulemaking related to Part 749, which covers the NCUA’s records preservation program requirements.

It’s important that federally insured credit unions maintain a robust records preservation program — a program whereby vital records can be readily reconstructed. Maintaining vital records is central to a credit union’s ability to properly serve its members and to the NCUA’s ability to fulfill its supervisory, enforcement, and liquidation functions.

It’s also important for credit unions to understand the necessary legal requirements and the agency’s guidance about records preservation.

Part 749 was last updated 15 years ago. Times change. Technology changes. There are modern needs and best practices that should be incorporated in policies for records retention and preservation.

For these reasons alone, I support this advance notice of proposed rulemaking and welcome comments from all stakeholders on how the NCUA can update, modernize, and streamline its records preservation program regulations and accompanying guidance.

Before I wrap up, I have a few questions for staff.

First, would you provide a few examples of what constitute vital records? That is, what records must a credit union preserve and why?

Thank you for those insights.

Second, would you provide an example of a current industry standard or methodology that should be considered for preserving vital records?

Thank you for that information as well.

Finally, with respect to Part 749 compliance, what has the NCUA done to make records retention more efficient?

Thank you again, Kelly, Matt, and Gira. And, thank you to everyone in the Office of Examination and Insurance and the Office of the General Counsel who worked on this item. That concludes my remarks. I now recognize Vice Chairman Hauptman.

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