CUNA Regulatory Comment Call


April 27, 2001

Advertising and Posting Notice of Nondiscrimination in Real Estate-Related Lending

EXECUTIVE SUMMARY

The National Credit Union Administration (NCUA) is seeking comments on a proposed rule that relaxes certain provisions in NCUA’s regulations concerning advertising and posting notice of nondiscrimination in real estate-related lending. Currently, NCUA regulations provide that a federal credit union (FCU) must include notice of nondiscrimination through use of one particular logotype and legend in written and visual advertisements and one particular phrase in oral advertisements.

The proposed rule would make the following changes:

Comments on the proposal are due to NCUA by June 25, 2001. Please submit your comments to CUNA by June 18, 2001. Please feel free to fax your responses to CUNA at 202-371-8240; e-mail them to Associate General Counsel Mary Dunn at mdunn@cuna.com or to Senior Regulatory Counsel Catherine Orr at corr@cuna.com; or mail them to Mary or Catherine in c/o CUNA's Regulatory Advocacy Department, 805 15th Street, NW, Suite 300, Washington, DC 20005. You may contact CUNA if you would like a copy of the proposed rule.

QUESTIONS REGARDING THE PROPOSAL

  1. Would the language change in the proposal to expressly require advertising for real estate-related lending to meet ECOA requirements significantly increase the compliance burden of your credit union in terms of time or cost?

    Yes ______ No ______

    If yes, can you quantify or describe this burden?















  2. Do the proposed modifications to the nondiscrimination rule provide sufficient flexibility for real estate-related advertising?

    Yes ______ No ______

    If not, what other modifications would you like to see incorporated into the rule?













  3. 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
Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com