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CUNA Regulatory Comment Call

November 22, 2002

EXECUTIVE SUMMARY

• At the November 21, 2002 NCUA Board meeting, the Board announced that the deadline for filing comments on the revised agency proposal concerning retirement benefits for employees of federal credit unions would be extended. CUNA had requested an extension of time for credit unions to comment. The original deadline for comments was November 25, 2002. Comments will now be due to the agency by December 26, 2002. Click here to see the Board's annoucement.
• Some have expressed concern with Subsection (d) of the revised proposal that would prohibit the use of variable funding arrangements (arrangements that have exposure to the stock market, such as mutual funds) to fund non-qualified defined benefit deferred compensation plans. We understand that about 50 federal credit unions offer these plans. They have used these types of plans (including discounted option plans under which they grant executives options to purchase certain property such as mutual fund shares at discounted prices at a future date) to supplement retirement income for their executives. Some are concerned that the subsection’s provisions would limit the ability of some credit unions to attract and retain talented executives. CUNA would especially like to hear from credit unions on this issue.
• CUNA’s Comment Call, which summarizes the revised proposal and contains a link to the text of the proposal, may be obtained by going to the following Internet address: http://www.cuna.org/reg_advocacy/reg_call/rcc_092602.html.
• If you have any questions about this revised proposal, please contact Associate General Counsel Mary Dunn (mdunn@cuna.com) or Senior Regulatory Counsel Catherine Orr (corr@cuna.com) by e-mail or by phone at 1-800-356-9655.