CUNA Regulatory Comment Call


March 23, 2005

CUSO Financial Statement Audits

EXECUTIVE SUMMARY

QUESTIONS REGARDING THE PROPOSAL

  1. NCUA indicates that the changes in this proposal are consistent with the agency’s ongoing efforts to reduce regulatory burden. Do you agree that this proposal would result in a significant reduction in burden for most CUSOs?

    Yes ______ No ______

    If not, why not? If so, could you quantify the reduction in burden?
















  2. Do you feel that NCUA’s CUSO rule should allow for a consolidated audit where an FCU owns only the majority share of the CUSO?

    Yes ______ No ______

    If yes, please explain why?
















  3. Are there other ways in which the proposal could be changed to further lessen the regulatory burden for CUSOs with regard to financial statements?

    Yes ______ No ______

    If yes, what are your suggestions?
















  4. Other comments?
















Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Associate 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