CUNA Comment Letter

NCUA's Proposed Changes to Community Development Revolving Loan Fund Program

February 20, 2001

Ms. Becky Baker
Secretary of the Board
National Credit Union Administration
1775 Duke Street
Alexandria, Virginia 22314

Dear Ms. Baker:

The Credit Union National Association appreciates the opportunity to comment on the National Credit Union Administration’s proposed and interim final changes to the Community Development Revolving Loan Program, under Section 705.10 of the agency’s rules.

Under the changes, NCUA is authorized to provide technical assistance to credit unions participating in the CDRLP directly or through outside providers selected by the credit unions or NCUA. Previously, NCUA’s rule did not authorize NCUA to provide technical assistance directly, although this may have been the practice. We believe the rule should be clarified to provide that if a credit union has selected a third party assistance provider, NCUA will not intervene in that selection process and will not require a credit union to use NCUA’s technical assistance as a condition of participating in the CDLRP. (Although the rule makes it clear that credit unions may receive technical assistance without obtaining a program loan, we believe the rule should nonetheless clarify that technical assistance from NCUA is not a requirement if a loan is sought.)

The amendments provide that NCUA will determine whether applications for technical assistance should be granted based on established procedures and standards that are publicly available. Credit unions should have the opportunity to comment on such procedures, and all applicants for technical assistance should be provided with a copy as part of the application process. They should also be more accessible on the agency’s main website, rather than just through the “Serving the Underserved-- link.

It was not easy for credit unions to comment on this proposal. It is not included in the agency’s list of proposed rules and is difficult to find on the agency’s website. We urge NCUA to ensure in the future that all agency proposals are easily accessible through NCUA’s website.

Thank you for the opportunity to comment on the proposed and interim final rule regarding the Community Development Revolving Loan Program.

Sincerely,

Mary Mitchell Dunn
Associate General Counsel and Senior Vice President