CUNA Regulatory Comment Call

February 1, 2007

NCUA’s 2007 Regulatory Review List

EXECUTIVE SUMMARY

QUESTIONS REGARDING THE INTERIM FINAL RULE

  1. Are there powers which you would like to see added to NCUA’s Incidental Powers rule?

    Yes____ No___


    If yes, what are those powers?
















  2. Are there additional RegFlex exemptions, such as including as exemptions the provisions that may be waived for member business loans, that you would suggest?

    Yes____ No___


    If yes, please explain the exemptions you would recommend.
















  3. Are there provisions in the member business loan rule (MBL) that could be revised to further facilitate member business lending? For example, some restrictions in the rule -- including loan to value ratios, aggregate construction and development loan limits and minimum borrower equity requirements for such loans are not specifically prescribed by statute. Rather than including these provisions in the rule itself, credit unions could address them in their required written policies, which are subject to review by their examiner.

    Yes____ No___


    If yes, how could NCUA more fully use its authority in this area to assist credit unions?
















  4. Do you have concerns regarding NCUA’s regulations implementing the Fair and Accurate Credit Transactions (FACT) Act?

    Yes____ No___


    If yes, what are those concerns?
















  5. Are there ways in which the agency’s privacy regulations could be revised to alleviate the burden associated with privacy notices?

    Yes____ No___


    If yes, please explain.
















  6. Other comments?
















Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Deputy General Counsel • (202) 508-6736 • mdunn@cuna.com
Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
Lilly Thomas • Assistant General Counsel • (202) 508-6733 • lthomas@cuna.com
Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com