CUNA Regulatory Comment Call


July 2, 2003

Proposed Revision of NCUA’s Loan Participation Rule

EXECUTIVE SUMMARY

QUESTIONS REGARDING THE PROPOSAL

  1. Do you agree that the definition of "credit union organization" should be modified in the loan participation rule to include CUSOs that "provide products and services related to the routine daily operations of credit unions and credit union members?"

    Yes ______ No ______

    Please explain why or why not.
















  2. Do you agree that the definition of financial organization in the loan participation rule should be broadened to include state and federal government agencies?

    Yes ______ No ______

    Please explain why or why not.
















  3. Are there other ways in which the rule should be modified to provide additional flexibility for credit unions seeking to engage in loan participations?

    Yes ______ No ______

    If yes, what modification(s) do you suggest?
















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