CUNA Regulatory Comment Call


August 4, 2005

RegFlex Program Eligibility – Minimum Net Worth Requirements

EXECUTIVE SUMMARY

BACKGROUND

QUESTIONS REGARDING THE PROPOSAL
  1. Do you agree with reducing the minimum net worth classification to qualify for RegFlex to “well capitalized”, which currently requires a minimum net worth of 7 percent?

    Yes____ No____

    If no, what should the minimum net worth required for RegFlex eligibility be?
















  2. Do you support the proposal’s provision extending the minimum number of quarters that the minimum net worth must be maintained to qualify for RegFlex to six consecutive quarters?

    Yes____ No____

    If no, what is the appropriate number of quarters the minimum net worth should be required to last before a credit union qualifies for RegFlex?
















  3. Do you agree that the requirement for NCUA to notify credit unions that automatically qualify for RegFlex is redundant and unnecessary?

    Yes____ No____

    If no, what are the potential problems with the elimination of the notification requirements?
















  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
Lilly Thomas • Assistant General Counsel • (202) 508-6733 • lthomas@cuna.com
Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com