CUNA Regulatory Comment Call


June 23, 2005

Sales of Nondeposit Investments

EXECUTIVE SUMMARY

BACKGROUND

DESCRIPTION OF THE PROPOSED IRPS

I. SEC (and NASD) Requirements

Physical Separation

Disclosures

Dual Employees

Compensation

Written Contract

II. Additional NCUA Requirements, Direction and Guidance

Due Diligence

Credit Union Policies, Procedures and Contracts

Dual Employees

Sales to Nonmembers

QUESTIONS REGARDING THE PROPOSED IRPS

  1. Do you feel the explanation of the physical separation requirement provides sufficiently clear/specific guidance?

    Yes_____ No_____

    Why or why not?
















  2. Do you agree with all of the disclosure requirements for brokers?

    Yes_____ No_____

    Why or why not?
















  3. Do you agree with the list of best practices for credit union policies, procedures and contracts concerning third-party brokerage arrangements?

    Yes_____ No_____

    If not, which best practice(s) do you think should be changed or excluded and why?
















  4. Do you have any concerns with the legal requirement for a credit union with such a brokerage agreement to have in place a program to monitor compliance of the brokerage salespeople with applicable laws and regulations as set forth in the proposal?

    Yes_____ No_____

    If yes, what are those concerns?
















  5. Do you feel the guidance on the separation of duties of dual employees as well as reimbursement is adequate?

    Yes_____ No_____

    If not, what specific aspect(s)need(s) more clarification?
















  6. Do you think the section on sales to nonmembers is overly restrictive?

    Yes_____ No_____

    Please explain.
















  7. 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