CUNA Comment Letter

Central Liquidity Facility

August 17, 1999

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

Re: Central Liquidity Facility

Dear Ms. Baker:

The Credit Union National Association (CUNA) appreciates the opportunity to comment on the National Credit Union Administration's (NCUA) notice updating and revising the terms and documents that reflect the repayment, security and credit reporting terms applicable to all Central Liquidity Facility (CLF) loans. The notice appeared in the Federal Register on July 29, 1999 and requested comment on five documents that govern all CLF liquidity loans.

CUNA concurs with the comments expressed by The Association of Corporate Credit Unions and commends the agency for soliciting industry input in revising and updating the forms. This process has resulted in documents that will help credit unions access CLF funds for emergency, back-up liquidity needs if Year 2000 related problems, such as unanticipated demand for member withdrawals, make that necessary. CUNA also commends the agency's timely revision of these documents in light of potential Year 2000-related liquidity demands.

Michelle Q. Profit
Assistant General Counsel