In another advocacy win this week, the NCUA has proposed a rule that would allow credit union board members to be reimbursed for any dependent caretaking expenses that were incurred as a result of board meetings or other official board member duties. The proposal was published on Monday in the Federal Register by lone NCUA board member and board chairman Kyle Hauptman.
America’s Credit Unions has been advocating for this measure for the last two years, with ACU Luke Martone writing to the NCUA in May 2024, asking for such a proposal to be considered. Martone argued that the time and place of board meetings (in the evenings, after work) coincide with when children are typically home and that, similarly to the cost of travel, the resulting childcare expenses are directly tied to the meeting and should therefore be reimbursed.
“Many credit unions schedule board meetings in the evenings, after the workday, or on weekends; however, this does not resolve childcare concerns. In fact, that is precisely when childcare would be needed for most volunteers as this falls outside of the standard hours for daycares or other paid caregiver services. Thus, this expense is inextricably tied to the travel required to attend a board meeting and should be reimbursable.”
While childcare was not deemed a reasonable expense previously, the letter points out that the last time the NCUA examined the rule was in 2001 to add for an additional travel guest, and the specific subject of childcare has not been considered since the 90s. In the decades since, family structures and childcare costs have changed significantly, it states.
Furthermore, the letter argues that without the added amendment, it is more difficult for women, single parents, individuals from low-income families, or heads of households with dependents to become credit union board members, due to the additional costs and complications, which goes against credit unions’ commitment to equity, inclusion, and diversity.
The simple solution, as suggested in the ACU letter, would be to “Update the existing limitation in section 701.33(b)(2)(i). This could be achieved by simply inserting ‘childcare’ into the last sentence of section 701.33(b)(2)(i) as follows: ‘Such payments may include the payment of childcare or travel costs for officials and one guest per official[.]'”
In the official proposal, the NCUA referenced the ACU letter as a primary driving force in its consideration of childcare reimbursement. It also acknowledged the struggle credit unions can have in securing qualified volunteers for the board positions, and thus a need to expand recruitment strategies and the potential volunteer pool, and adding childcare costs would achieve both. Additionally, the NCUA agreed that the shift in family dynamics and childcare costs since 2001 has made the previous rule outdated.
In its request for comments, the NCUA has listed 12 questions for credit unions to consider and respond to. The full proposal, as well as the suggested questions for commentary, can be viewed in the Federal Register. The proposal will be open for comments until March 27th.
