CUNA Regulatory Comment Call


February 23, 2006

NCUA’s Request for Comment on the Submission to OMB for Review of the Pilot Program to Measure Service to Members

  • The National Credit Union Administration (NCUA) is requesting comments on its pilot program for collecting data from a sample of federal credit unions as a means to measure service to members of modest means. This is in connection with NCUA’s submission to the Office of Management and Budget (OMB) for review and clearance of its request to collect the information, which is required under the Paperwork Reduction Act of 1995. NCUA has requested comments as part of this process.
  • NCUA recently announced that it will gather information from 481 federal credit unions regarding service to members. This initiative is in response to questions on this issue that were raised during the November 3, 2005 Congressional hearing on the credit union tax exemption.
  • The data collection will focus on the following three areas:
    • Compensation levels for the top three executives in the credit union.
    • An estimate of income levels of credit union members.
    • Other information the credit union may have regarding service to members of modest means.
  • The data will be collected as part of the examination process. It will be collected on an aggregate basis, and NCUA has provided assurances that the information will be kept strictly confidential. More information from NCUA about this process can be found here.
  • In the submission to OMB, NCUA has estimated that it will take one hour for each federal credit union to provide the requested information.
  • Comments must be submitted on or before February 28, 2006. If submitting comments directly to NCUA, please direct them to the following:
    Mr. Neil McNamara
    Clearance Officer
    National Credit Union Administration
    1775 Duke Street
    Alexandria, Virginia 22314-3428
    Phone: (703) 518-6447
    Fax: (703) 518-6489
    Email: mcnamara@ncua.gov
  • Please also feel free to fax your responses to CUNA at 202-638-7052; e-mail them to Senior Vice President and Associate General Counsel Mary Dunn at mdunn@cuna.com and to Senior Assistant General Counsel Jeff Bloch at jbloch@cuna.com; or mail them to Mary and Jeff in c/o CUNA’s Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, South Building, Suite 600, Washington, DC 20004-2601. You may also contact us at 800-356-9655, ext. 6032, if you would like a copy of the request for comment, or you may access it here.

QUESTIONS TO CONSIDER REGARDING NCUA’s PILOT PROGRAM AND REQUEST FOR REVIEW FROM OMB

  • Do you believe one hour is an accurate estimate of the time necessary to collect the requested information? What would be your estimate of the time necessary to provide this information?
















  • Other comments?
















Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Deputy General Counsel • (202) 508-6736 • mdunn@cuna.com
Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
Lilly Thomas • Assistant General Counsel • (202) 508-6733 • lthomas@cuna.com
Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com
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