CUNA Regulatory Comment Call

April 21, 2008

NCUA Requests Comment on Proposed Revisions to CUSO Regulations

EXECUTIVE SUMMARY

NCUA is proposing to amend its credit union service organization (CUSO) regulations by expanding and clarifying permissible CUSO activities. In addition, the proposed rule would give NCUA access to the books and records of CUSOs that are owned by federally-insured, state-chartered credit unions (FISCUs); require FISCUs to maintain a separate corporate identity from their CUSOs; and would limit the ability of undercapitalized federal credit unions (FCUs) to recapitalize a CUSO. Comments are due to NCUA by June 30, 2008. Please submit your comments to CUNA by June 7, 2008.

QUESTIONS TO CONSIDER REGARDING THE NCUA IRPS
(NCUA has requested comment on these specific issues)

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
Luke Martone • Senior Regulatory Counsel • (202) 508-6743 • lmartone@cuna.com