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CUNA Regulatory Comment Call

September 25, 2001

Executive Summary

• On September 13, 2001, the National Credit Union Administration (NCUA) Board approved a proposed rule governing corporate credit unions. The NCUA Board has previously issued two advance notices of proposed rulemakings (ANPRs). The current proposed rule incorporates comments received in response to the earlier ANPRs.
• Click here for more information on the proposed rule, which has been provided by the Association of Corporate Credit Unions (ACCU).
• Comments are due by December 20, 2001. Please submit your comments to CUNA by December 13, 2001.
• Please feel free to fax your responses to CUNA at 202-371-8240; e-mail them to Associate General Counsel Mary Dunn at mdunn@cuna.com or to Assistant General Counsel Jeffrey Bloch at jbloch@cuna.com; or mail them to Mary or Jeff in c/o CUNA’s Regulatory Advocacy Department, 805 15th Street, NW, Suite 300, Washington, DC 20005. Please contact us if you need more information. You may also contact us if you would like a copy of the proposed rule or you may access it on the Internet at the following address: http://www.ncua.gov/RegulationsOpinionsLaws/proposed_regs/12CFRParts703and704-proposed.htm

• The proposed rule will limit a natural person credit union’s purchase of paid-in capital (PIC) and membership capital (MC) in a corporate credit union to an amount up to two percent of the credit union’s assets (the current limit is one percent). Do you support this new limit? Also, the proposed rule will limit a credit union’s aggregate purchase of PIC and MC in all corporates to an amount not exceeding four percent of the credit union’s assets. Is this a reasonable limitation?




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• In addition to services that corporates may now provide to member credit unions, the proposed rule will add four additional broad categories of services - - asset and liability management; electronic financial services; sale or lease of excess physical or information system capacity; and operational services associated with administering or providing financial products or services. Are there other services that corporates should be permitted to provide to their member credit unions?




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• The proposed rule will allow corporates to enter into loan participations with their member credit unions. The amount of participations with one credit union will be limited to 25% of the corporate’s capital and participations with all credit unions may not exceed 100% of the corporate’s capital. Do you support this loan participation authority and do you have any concerns regarding the limitations?




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• Other comments




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