CUNA Regulatory Comment Call
September 25, 2001
NCUA Proposed Rule for Corporate Credit Unions(MAJOR RULE FOR CORPORATE CREDIT UNIONS)
- On September 13, 2001, the National Credit Union Administration (NCUA) Board approved a proposed rule governing corporate credit unions. The NCUA Board has previously issued two advance notices of proposed rulemakings (ANPRs). The current proposed rule incorporates comments received in response to the earlier ANPRs.
- Click here for more information on the proposed rule, which has been provided by the Association of Corporate Credit Unions (ACCU).
- Comments are due by December 20, 2001. Please submit your comments to CUNA by December 13, 2001.
- Please feel free to fax your responses to CUNA at 202-371-8240; e-mail them to Associate General Counsel Mary Dunn at firstname.lastname@example.org or to Assistant General Counsel Jeffrey Bloch at email@example.com; or mail them to Mary or Jeff in c/o CUNAs Regulatory Advocacy Department, 805 15th Street, NW, Suite 300, Washington, DC 20005. Please contact us if you need more information. You may also contact us if you would like a copy of the proposed rule or you may access it on the Internet at the following address: http://www.ncua.gov/RegulationsOpinionsLaws/proposed_regs/12CFRParts703and704-proposed.htm
QUESTIONS TO CONSIDER REGARDING NCUAs PROPOSED RULE FOR CORPORATE CREDIT UNIONS
- The proposed rule will limit a natural person credit unions purchase of paid-in capital (PIC) and membership capital (MC) in a corporate credit union to an amount up to two percent of the credit unions assets (the current limit is one percent). Do you support this new limit? Also, the proposed rule will limit a credit unions aggregate purchase of PIC and MC in all corporates to an amount not exceeding four percent of the credit unions assets. Is this a reasonable limitation?
- In addition to services that corporates may now provide to member credit unions, the proposed rule will add four additional broad categories of services - - asset and liability management; electronic financial services; sale or lease of excess physical or information system capacity; and operational services associated with administering or providing financial products or services. Are there other services that corporates should be permitted to provide to their member credit unions?
- The proposed rule will allow corporates to enter into loan participations with their member credit unions. The amount of participations with one credit union will be limited to 25% of the corporates capital and participations with all credit unions may not exceed 100% of the corporates capital. Do you support this loan participation authority and do you have any concerns regarding the limitations?
- Other comments
Eric Richard General Counsel (202) 508-6742 firstname.lastname@example.org |
Mary Mitchell Dunn SVP & Associate General Counsel (202) 508-6736 email@example.com
Jeffrey Bloch Assistant General Counsel (202) 508-6732 firstname.lastname@example.org
Catherine Orr Senior Regulatory Counsel (202) 508-6743 email@example.com