CUNA Regulatory Comment Call


December 17, 2001

NCUA’S PROPOSAL ON RETIREMENT BENEFITS FOR EMPLOYEES OF FEDERAL CREDIT UNIONS

EXECUTIVE SUMMARY

The NCUA Board unanimously approved the issuance of a proposal amending its rule that permits a federal credit union (FCU) to provide reasonable retirement benefits to its employees and officers. In the proposed rule, NCUA clarifies that the scope of the rule is not limited only to retirement benefits but is more broadly applicable to other employee benefit plans. The intent of the proposed rule is to provide FCUs with flexibility to use safe, reasonable and efficient methods to fund their employee benefit obligations.

The following are the main provisions of the proposal:

QUESTIONS REGARDING THE PROPOSAL

  1. The proposal notes that as competition to attract and retain qualified employees has increased and the employee benefits marketplace has become more sophisticated, FCUs are increasingly providing more diverse and less traditional forms of employee benefits (such as deferred compensation plans and stock option plans). NCUA intends this proposal to provide needed flexibility to credit unions to fund their employee benefit obligations. Do you agree the proposal provides enough flexibility for your credit union to adequately fund employee benefit obligations given the competitive marketplace?














  2. Yes ______ No ______

    If not, what other modifications would you like to see incorporated into the rule to make it more flexible













  3. Are there any other changes NCUA could adopt to make it easier for credit unions to manage their employee benefit plans?













    Yes ______ No ______

    If so, what are those changes?














  4. Are there any other things NCUA could do to assist credit unions in attracting and retaining highly qualified employees















  5. Yes ______ No ______

    If so, what are they?














  6. Other comments?














Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Associate General Counsel • (202) 508-6736 • mdunn@cuna.com
Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com