CUNA Regulatory Comment Call


July 26, 2004

Extension of Comment Period for Proposal Granting Credit Unions Some Broker-Dealer Exemptions Given Banks

(A Major Proposal)

EXECUTIVE SUMMARY

The Securities and Exchange Commission (SEC) has issued a proposed rule ("Regulation B") that would grant credit unions some of the exemptions from the broker-dealer registration requirements that banks currently receive and provide new exemptions for banks. These exceptions are provided under the Securities Exchange Act of 1934 "Exchange Act," as amended by the Gramm-Leach-Bliley Act ("GLBA"). At the urging of CUNA and other trade associations, the proposal grants credit unions three exceptions, whereby they could conduct certain securities-related activities without registering as a broker or dealer.

Please feel free to fax your responses to CUNA at 202-638-7052; or e-mail them to Associate General Counsel Mary Dunn at mdunn@cuna.com and to Assistant General Counsel Michelle Profit at mprofit@cuna.com; or mail them to Mary and Michelle c/o CUNA’s Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, South Building, Suite 600, Washington, D.C. 20004. You may also access the announcement to extend the comment period at http://www.sec.gov/rules/proposed/34-50056.htm

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