CUNA Regulatory Comment Call


October 27, 2006

General Lending Maturity Limit and Providing Certain Services to Nonmembers Under the Regulatory Relief Act

EXECUTIVE SUMMARY

QUESTIONS REGARDING THE INTERIM FINAL RULE

  1. Besides the PCA rule’s references to the 12-year unsecured loan term, are there any other provisions in NCUA’s rules that need to be modified to conform with the Reg Relief provisions on general loan maturity limits?

    Yes ____ No ____

    If yes, what are those regulatory provisions?
















  2. Are there any specific provisions in NCUA’s rules that should be revised to facilitate FCUs providing the enumerated financial services to anyone eligible for membership in the credit union regardless of membership status, such as obligations concerning privacy notices?

    Yes ____ No ____

    If yes, please explain.
















  3. Other comments?
















Eric Richard • EVP &General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Deputy General Counsel • (202) 508-6736 • mdunn@cuna.com
Jeffrey Bloch • Senior 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