CUNA Regulatory Comment Call


July 17, 2003

Agency Review to Reduce Regulatory Burden

EXECUTIVE SUMMARY

QUESTIONS REGARDING THE REQUEST FOR COMMENTS

    Need and Purpose of the Regulations

  1. Do the regulations in the 2 categories fulfill current needs of credit unions?

    Yes ______ No ______

    Please explain.
















  2. Have industry or other circumstances changed since a regulation was written such that the regulation is no longer necessary?

    Yes ______ No ______

    Please explain.
















  3. Have there been shifts within the industry or consumer actions that suggest a re-focus of the underlying regulations?

    Yes ______ No ______

    Please explain.
















  4. Do any of the regulations in these 2 categories impose burdens not required by their authorizing statutes?

    Yes ______ No ______

    Please explain.
















    Need for Statutory Change


  5. Do the statutes underlying the regulations in the 2 categories under review impose unnecessary requirements?

    Yes ______ No ______

    Please explain.
















  6. Are any of the statutory requirements underlying these categories redundant, conflicting or otherwise unduly burdensome?

    Yes ______ No ______

    Please explain.
















    Overreaching Approaches/Flexibility of the Regulatory Standards


  7. Generally, is there a different approach to regulating that NCUA could use that would achieve statutory goals while imposing less burden?

    Yes ______ No ______

    Please explain.
















  8. Do any of the regulations in these categories or the statutes underlying them impose unnecessarily inflexible requirements?

    Yes ______ No ______

    Please explain.
















    Effect of the Regulations on Competition


  9. Do any of the regulations in these categories or the statutes underlying them create competitive disadvantages for credit unions compared to another part of the financial services industry?

    Yes ______ No ______

    Please explain.
















    Reporting, Recordkeeping and Disclosure Requirements


  10. Do any of the regulations in these categories or the statutes underlying them impose particularly burdensome reporting, recordkeeping or disclosure requirements?

    Yes ______ No ______

    Please explain.
















  11. Are any of these requirements similar enough in purpose and use so that they could be consolidated?

    Yes ______ No ______

    Please explain.
















  12. Could any of the requirements under the rules in these 2 categories be fulfilled electronically to reduce their burden?

    Yes ______ No ______

    Please explain.
















    Consistency and Redundency


  13. Do any of the regulations in these categories impose inconsistent or redundant regulatory requirements that are not warranted by the circumstances?

    Yes ______ No ______

    Please explain.
















    Clarity


  14. Are the regulations in these categories and the underlying statutes drafted in clear and easily understood language?

    Yes ______ No ______

    Please explain.
















  15. Are there specific regulations or underlying statutes that need clarification?

    Yes ______ No ______

    Please explain.
















    Burden on Small Insured Institutions


  16. NCUA has a particular interest in minimizing burden on small credit unions (those with less than $10 million in assets). Should any of the regulations within the 2 categories be continued without change, or should any of the regulations be amended or rescinded in order to minimize any significant economic impact the regulations may have on a substantial number of small federally-insured credit unions?

    Please explain.
















    Other


  17. 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