Archive - 1998 Comment Letters

Current Comment Letters

Archive: 1999-2013


Proposed Changes to NCUA's Regulation on Eligible Obligations
(October 5, 1998)
CUNA provided comments on NCUA's proposal to amend Section 701.23(b) of the agency's regulations governing the purchase, sale and pledge of eligible obligations.

Proposed Changes to NCUA's Lending Regulation to address Real Estate Assumptions by Non-Members
(October 5, 1998)
CUNA supported NCUA's proposal to include the substance of Interpretive Ruling and Policy Statement (IRPS) 85-3 into Section 701.21(g) of the agency's regulations. The amendment would permit real estate assumptions by non-members in connection with the purchase of a FCU member's home.

NCUA's Interim Final Rule and Request for Comments on Roth and Education IRAs.
(May 20, 1998)
CUNA urged the NCUA Board to adopt the interim final rule on Section 724.1 of the agency's regulations, which would authorize federal credit unions to offer new IRA products.


Advance Notice of Proposed Rulemaking on Regulation B (Equal Credit Opportunity), Docket No. R-1008
(May 29, 1998)
CUNA responded to the Federal Reserve Board's request for comments on whether it should revise the Regulation B to address technological and other developments, better balance consumer protection and industry burden, and delete obsolete provisions.

Advance Notice of Proposed Rulemaking on Regulation C (Home Mortgage Disclosure), Docket No. R-1001
(May 28, 1998)
CUNA urged that the Federal Reserve Board make no changes to the HMDA-LAR codes or to the HMDA data collection and reporting requirements. Doing so would necessitate expensive changes to credit unions' data collection systems and require staff retraining.

Proposed Amendments to Regulation Z (Truth in Lending) - Electronic Delivery of Disclosures, Docket No. R-1005
(May 15, 1998)
CUNA supported the Federal Reserve Board's efforts to provide guidance on the electronic delivery of Regulation Z disclosures, and offered specific comments regarding each of the proposed amendments to the regulation.

Proposed Amendments to Regulation M (Consumer Leasing Act) - Electronic Delivery of Disclosures, Docket No. R-1004.
(May 15, 1998)
CUNA supported the Federal Reserve Board's proposal as providing flexibility as standards are developed for establishing legal agreements by electronic communications.

Proposed Amendments to Regulation B (Equal Credit Opportunity) - Electronic Delivery of Disclosures, Docket No. 1006
(May 15, 1998)
CUNA supported the Federal Reserve Board's proposal, which would permit creditors to use electronic communications to provide the required consumer disclosures.

Interim Rule and Request for Comments on Regulation E (Electronic Funds Transfer) - Electronic Delivery of Disclosures, Docket No. R-1002
(May 15, 1998)
CUNA supported allowing financial institutions to provide Regulation E disclosures electronically, and offered comments on the interim rule's specific provisions.


Proposed Rule on Federal Government Participation in the Automated Clearinghouse.
(May 4, 1998)
CUNA commented on Financial Management Service's (Treasury Department) proposed rule governing the use of the Automated Clearinghouse (ACH) system by Federal agencies. CUNA generally supported the Service's determination that the ACH rules, which apply to private entries made through the system, should also apply to credit and debit entries originated and received by Federal agencies.


Fair Debt Collection Practices Act Proposal.
(June 19, 1998)
The FTC is reviewing the overall costs and benefits and the continuing need for its Procedures for State Application for Exemption from the Provisions of the Fair Debt Collection Practices Act. CUNA urged the agency to maintain the procedures for the state exemption at the least cost and burden to the states applying for the option.


Proposal to Change Voting Requirements for Federally Chartered Mutual Savings Associations
(June 15, 1998)
CUNA opposed the Office of Thrift Supervision's proposal to allow mutual savings associations to set the number of votes per member within the range of 1 to 1000.

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