CUNA Regulatory Comment Call
August 2, 1999
Central Liquidity Facility Loan Forms
The National Credit Union Administration (NCUA) requests comments on the five forms that can be used to request a loan from the Central Liquidity Facility (CLF). The NCUA published a notice of request for comments on Thursday, July 29, and requests comments on or before August 18, 1999. Please submit your comments to CUNA by August 16, 1999, by fax at 202/371-8240 or by e-mail to CUNA's Assistant General Counsel Michelle Profit at firstname.lastname@example.org. You may also contact CUNA if you would like a copy of this Federal Register notice or you may access it on the Internet.
The purpose of the CLF is to improve the general stability of credit unions by meeting their liquidity needs. As a result of the approach of the year 2000, CLF recognizes that the liquidity needs of credit unions may increase dramatically. Accordingly, CLF has revised the repayment security, and credit reporting (RSCR) terms applicable to all CLF liquidity loans.
The NCUA is updating the RSCR terms and revising the complementary CLF forms. In addition, NCUA is adding two new forms, so that in the future, five revised forms will be available for CLF liquidity loans. NCUA regulations require publishing any modifications to the RSCR terms and forms in the Federal Register. Consequently, the NCUA has asked for comments on the redrafted Request for Funds Form, the Liquidity Need Loan Application, the CLF Agent Member Application Form, Agent Member RSCR Agreement and Agent Group Representative RSCR Agreement.
Specifically, the Request for Funds Form serves as the official document to request a liquidity loan from the CLF. This form may be submitted by a corporate credit union that is an agent member of the CLF (Agent Member) or an Agent Group Representative, who serves as the representative for a group of corporate credit unions. This form includes the information necessary to process a liquidity loan, including the identity of the natural person credit union borrower, the loan amount, and the purpose for the loan. The Liquidity Need Loan Application contains the terms and conditions of the relationship between an Agent Member, its natural person credit union member, and its Agent Group Representative in the context of requesting liquidity loans. The CLF Agent Member Application Form is to be used by corporate credit unions that wish to apply for Agent Member status. The Agent Member RSCR Agreement contains the terms and conditions of the relationship between an Agent Member and the CLF in the context of transacting CLF liquidity loans. The Agent Group Representative RSCR Agreement contains the terms and conditions of the relationship between an Agent Group Representative and the CLF in the context of transacting CLF liquidity loans.
QUESTIONS REGARDING THE FORMS
QUESTIONS TO CONSIDER REGARDING NCUA'S CORPORATE CREDIT UNION PROPOSAL
- Should the forms be changed? If so, which forms would you change? How you would change the form(s)?
- Are the questions that the forms ask clear and unambiguous? If not, which forms are ambiguous? How would you change the form(s)?
Eric Richard General Counsel (202) 508-6742 email@example.com |
Mary Mitchell Dunn SVP & Associate General Counsel (202) 508-6736 firstname.lastname@example.org
Jeffrey Bloch Assistant General Counsel (202) 508-6732 email@example.com
Catherine Orr Senior Regulatory Counsel (202) 508-6743 firstname.lastname@example.org