CUNA Regulatory Comment Call


April 19, 2004

Student Credit Unions Made Eligible for Community Development Loans
(Not a Major Rule)

EXECUTIVE SUMMARY

Please feel free to fax your responses to CUNA at 202-638-7052; e-mail them to Associate General Counsel Mary Dunn at mdunn@cuna.com and to Assistant General Counsel Michelle Profit at mprofit@cuna.com; or mail them to Mary and Michelle c/o CUNA’s Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, South Building, Suite 600, Washington, D.C. 20004. You may also access the proposed rule at: http://www.ncua.gov/RegulationsOpinionsLaws/proposed_regs/proposed_regs.html

DISCUSSION

The amendment to the Community Development Revolving Loan Program for Credit Unions (CDRLP) would permit student credit unions to apply for loans and assistance within the program. The purpose of the CDRLP is to support the community development activities of participating credit unions, which are the designated credit unions that stimulate economic development and community revitalization activities in the communities they serve, or the designated credit unions with a predominantly low-income membership. Although this amendment makes student credit unions eligible to apply, it does not guarantee their selection.

Historically, NCUA has taken the position that although student credit unions are designated as low-income credit unions for purposes of receiving nonmember deposits, they do not qualify to participate in the CDRLP because they are not specifically involved in the stimulation of economic activities and community revitalization. NCUA has now concluded that well run student credit unions would benefit greatly from participation in the CDRLP and, as a result, would be better able to serve their communities.

Comments on this proposal will be due 30 days after it is published in the Federal Register, which should be within the next few days. This short comment period may allow for student credit unions to submit applications within the current fiscal year, if the amendment is adopted.

QUESTIONS REGARDING THE PROPOSAL

  1. Does your credit union support the change to allow student credit unions to apply for loans and technical assistance in the CDLRP? Please explain.
















  2. Would this policy benefit or hurt credit unions? Please explain.
















  3. Do you have any additional comments on this proposal or the CDLRP regulations?
















  4. Please submit your name, address, and phone number.
















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
Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com