CUNA Regulatory Comment Call


November 30, 2006

Share Insurance Appeals and NCUA Enforcement Authority

EXECUTIVE SUMMARY

QUESTIONS REGARDING THE INTERIM FINAL RULE

  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 • 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