CUNA Comment Letter

CUNA GUIDELINES FOR THE NCUA BOARD ON THE ENFORCEMENT OF FEDERAL CREDIT UNION BYLAWS

The CUNA Examination and Supervision Subcommittee developed the following guidelines for bylaw enforcement which have been reviewed by CUNA’s Governmental Affairs Committee and adopted as policy by CUNA’s Executive Committee. These guidelines recognize that NCUA has the legal authority to enforce bylaws, but due to number of practical and operational concerns, they oppose NCUA’s enforcement of bylaws that do not address members’ fundamental rights and merely address administrative issues. The guidelines also seek to preclude the potential for NCUA examiners to intrude, under the auspices of bylaw regulation, into the daily affairs of a credit union.

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