CUNA Regulatory Comment Call


July 16, 2004

Agency Review to Reduce the Burden of Consumer Protection Rules

(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.coop and to Assistant General Counsel Jeff Bloch at jbloch@cuna.coop; or mail them to Mary and Jeff in c/o CUNA’s Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, South Building, Suite 600, Washington, DC 20004-2601. You may also contact us at 800-356-9655, ext. 6732, if you would like a copy of the request for comments, or you may access them on the Internet at the following address:

http://www.ncua.gov/RegulationsOpinionsLaws/proposed_regs/ProposedEGRPRA3.pdf

BACKGROUND

NCUA and the other federal financial institution regulators are required by EGRPRA to review their rules at least once every ten years. EGRPRA requires the regulators to categorize the rules, publish the categories for comment, report to Congress on any significant issues raised by the comments, and eliminate unnecessary rules.

BRIEF DESCRIPTION OF THE REQUEST FOR COMMENTS

The NCUA Board has issued a request for comments to identify outdated, unnecessary, or burdensome regulatory requirements imposed on federally insured credit unions. Because the credit union system differs from the banking system, NCUA will publish its notices separately but maintain comparability with the other regulators to the extent the issues are the same. The EGRPRA review supplements and complements the regulatory review that NCUA conducts under other laws and its internal policies.

NCUA will seek comments on a number of categories of rules between now and 2006. NCUA and the other regulators are now seeking comments on the following consumer protection rules:

NCUA encourages all comments with regard to these rules. Specifically, comments are encouraged with regard to the following issues:

Comments are requested not only on the burden imposed by individual regulatory requirements, but also on the cumulative effect of these rules. NCUA also encourages comments that pertain to product lines. For example, for a specific type of share account, this could address whether a disclosure requirement under one rule is inconsistent with or duplicative of requirements under another rule. Comments on such product lines may also include recommendations about rules that are not included in the current request for comments.

At the conclusion of the comment period, NCUA and the other regulators will review the comments received and will consider proposing amendments to these rules. Comments that may also require statutory changes are also encouraged. A report will be submitted to Congress discussing the issues raised in the comments and whether they must be addressed by legislative or regulatory changes.

QUESTIONS TO CONSIDER REGARDING THE REQUEST FOR COMMENTS
(NCUA Specifically Requests Comments on the Following Issues)

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
Michelle Profit • Assistant General Counsel • (202) 508-6733 • mprofit@cuna.com
Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com