CUNA Comment Letter

CUNA's Letter on the Proposed Amendments to Interpretive Rule and Policy Statement IRPS 99-1 (IRPS 00-1)

June 28, 2000

Ms. Becky Baker
Secretary of the Board
National Credit Union Administration
1775 Duke Street
Alexandria, VA 22314-3428

Re: Request for Extension of Comment Period on Proposed Amendments to Interpretive Rule and Policy Statement IRPS 99-1 (IRPS 00-1)

Dear Ms. Baker:

At the NCUA Board Meeting on June 6, 2000, NCUA issued for public comment proposed amendments to its chartering and field of membership manual. This proposal was recently published in the Federal Register with a request that comments be received or postmarked by August 14, 2000. The Credit Union National Association (CUNA) respectfully requests an extension of the comment period until October 13, 2000.

The proposed amendments contain a series of broad-based revisions to the chartering and field of membership manual. Of particular importance is the revision that would affect new and existing community federal credit unions directly by requiring them to develop and maintain a community action plan (CAP) that would be used by NCUA to evaluate how well these credit unions are serving their entire community.

Even though the proposed CAP requirement would only apply to community federal credit unions, the entire credit union movement is very concerned about the impact of the proposal on all credit unions. These concerns range from possible expansion of this requirement beyond community federal credit unions to possible implications regarding the value of the federal charter. These complex issues will require detailed analysis for purposes of developing well-reasoned comments and possible alternatives that will meet the needs of both NCUA and the credit union movement. We are concerned that such analysis will not be completed prior to August 14, 2000.

In the recent past, NCUA has extended the comment period for both the proposed prompt corrective action and member business loan rules. The complexity of the proposed amendments to the chartering and field of membership manual is similar in nature, which we believe justifies extending the comment period for an additional 60 days.

We appreciate the NCUA Board’s consideration of our request for an extension of the comment period. If you or NCUA staff wish to discuss this issue further, please contact me at (202) 218- 7796.


Eric Richard
General Counsel

cc: The Honorable Norman E. D’Amour, NCUA Board Chairman
The Honorable Dennis Dollar, NCUA Board Member
The Honorable Yolanda Townsend Wheat, NCUA Board member
Chris Kerecman, Vice President – Federal Governmental Affairs, California and Nevada Credit Union League