CUNA Regulatory Comment Call

November 30, 2006

Share Insurance Appeals and NCUA Enforcement Authority



  1. Do you agree that the proper judicial venue for appeals from a final Board decision regarding share insurance coverage should be the appropriate U.S. District Court (a lower court than the appropriate U.S. Court of Appeals)? Yes No

    If no, why not?

  2. Do you have any concerns with respect to broadening the NCUA Board’s authority to take enforcement actions – including termination of insured status -- for violation of any condition imposed in any action on any application, notice, or other request by an institution-affiliated party? Yes No

    If yes, what are those concerns?

  3. Do you agree with the new modified provision clarifying that the NCUA Board has the authority to issue Orders against an individual who is an institution-affiliated party even if the individual is no longer affiliated with any credit union at the time the Board considers or issues the Order? Yes No

    Please explain.

  4. Other comments?

Eric Richard • EVP &General Counsel • (202) 508-6742 •
Mary Mitchell Dunn • SVP & Deputy General Counsel • (202) 508-6736 •
Jeffrey Bloch • Senior Assistant General Counsel • (202) 508-6732 •
Lilly Thomas • Assistant General Counsel • (202) 508-6733 •
Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 •