CUNA Regulatory Comment Call

November 5, 2010

Interim Final Rule: PCA – Amended Definition of Low-Risk Assets

Summary of Interim Final Rule

Please send comments on the interim final rule to Senior Vice President and Deputy General Counsel Mary Dunn and Regulatory Counsel Luke Martone, or contact us at (800) 356-9655 ext. 6743 with any questions.

Questions to Consider Regarding the Interim Final Rule

  1. The interim final rule expands the PCA definition of “low-risk assets” to include NCUA-guaranteed debt instruments, such as the NGNs. Do you agree with NCUA that this change was necessary?
















  2. Do you have any specific concerns related to the expanded definition of “low-risk assets?”
















  3. Do you have any other comments or questions regarding the interim final rule?
















Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Deputy General Counsel • (202) 508-6736 • mdunn@cuna.com
Luke Martone • Senior Regulatory Counsel • (202) 508-6743 • lmartone@cuna.com