CUNA Regulatory Comment Call
October 27, 2008
NCUA Proposed Rule on Share Insurance Signs for Shared Branching
- The NCUA Board approved a proposed rule for a thirty-day comment period to amend the share insurance sign requirements for federally insured credit unions participating in shared branching networks. Currently, for tellers accepting share deposits for both federally insured and nonfederally insured credit unions, there must be a second sign adjacent to the official NCUA insurance sign. The second sign must list each federally insured credit union served by the teller, along with a statement that only these credit unions are federally insured.
- The proposed rule will replace the required list of credit unions with a general statement that not all of the credit unions served by the teller are federally insured and members should contact their credit union for further information. This proposal recognizes the burden of the current requirements for those shared branch networks that are national in scope, which may serve thousands of individual credit unions. This often results in lengthy signs that need to be updated frequently.
- Under the proposal, the revised second sign must be similar to the current official NCUA sign in terms of design, color, and font. NCUA will produce signs that meet these new requirements and will make them available at a reasonable cost.
- The proposal will also clarify that tellers in nonfederally insured credit union branches may accept deposits for federally insured credit unions as part of a shared branching network. However, these credit union branches may not display the official NCUA sign and there would, therefore, be no need to display the second sign.
- Comments are due by November 21, 2008. Please submit your comments to CUNA by November 17, 2008.
Please feel free to fax your responses to CUNA at 202-638-7052; e-mail them to Senior Vice President and Deputy General Counsel Mary Dunn at firstname.lastname@example.org and to Senior Assistant General Counsel Jeff Bloch at email@example.com; or mail them to Mary and Jeff in c/o CUNAs Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, South Building, Suite 600, Washington, DC 20004-2601. You may also contact us at 800-356-9655, ext. 6732, if you have questions or would like a copy of the interim final rule. You may also access it on the Internet at the following address: "http://www.ncua.gov/RegulationsOpinionsLaws/proposed_regs/Proposed%20rule%20text%20740%204%20for%20web.pdf".
QUESTIONS TO CONSIDER REGARDING
THE SHARE INSURANCE SIGN PROPOSAL
- NCUA has requested comments to help the agency understand the inner workings of shared branching. Please provide any information you may have that will help NCUA in this area.
- Is the proposal adequate to ensure that credit union members understand the insurance status of their credit union accounts?
- Other comments?
Eric Richard General Counsel (202) 508-6742 firstname.lastname@example.org |
Mary Mitchell Dunn SVP & Deputy General Counsel (202) 508-6736 email@example.com
Jeffrey Bloch Assistant General Counsel (202) 508-6732 firstname.lastname@example.org
Lilly Thomas Assistant General Counsel (202) 508-6733 email@example.com
Luke Martone Senior Regulatory Counsel (202) 508-6743 firstname.lastname@example.org