CUNA Regulatory Comment Call


December 30, 2005

Agency Review to Reduce Regulatory Burdens
(Not a Major Rule)

EXECUTIVE SUMMARY

Please feel free to fax your responses to CUNA at 202-638-7052; e-mail them to Associate General Counsel Mary Dunn at mdunn@cuna.coop and to Assistant General Counsel Lilly Thomas at lthomas@cuna.coop; or mail them to Mary and Lilly in c/o CUNA’s 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. 6733, if you would like a copy of the request for comments, or you may access them here.

BACKGROUND

NCUA and the other federal financial institution regulators are required by EGRPRA to review their rules at least once every ten years. EGRPRA requires the regulators to categorize the rules, publish the categories for comment, report to Congress on any significant issues raised by the comments, and eliminate unnecessary rules. NCUA will request comments on certain categories of rules every six months between 2003 and 2006.

BRIEF DESCRIPTION OF THE REQUEST FOR COMMENTS

The NCUA Board has issued a request for comments to identify outdated, unnecessary, or burdensome regulatory requirements imposed on federally insured credit unions. Because the credit union system differs from the banking system, NCUA will publish its notices separately but maintain comparability with the other regulators to the extent the issues are the same. The EGRPRA review supplements and complements the regulatory review that NCUA conducts under other laws and its internal policies.

NCUA sought comments on a number of categories of rules since 2003. This is the sixth and final notice required by EGRPRA. NCUA and the other regulators are now seeking comments on the following regulatory categories:

NCUA encourages all comments with regard to these rules. Specifically, comments are encouraged with regard to the following issues:

In addition to comments on individual rules and requirements, NCUA also encourages comments that pertain to product lines. This should be helpful in exposing redundant and potentially inconsistent regulatory requirements and Comments on such product lines may also include recommendations about rules that are not included in the current request for comments.

At the conclusion of the comment period, NCUA and the other regulators will review the comments received and will consider proposing amendments to these rules. Comments that may also require statutory changes are also encouraged. A report will be submitted to Congress discussing the issues raised in the comments and whether they must be addressed by legislative or regulatory changes.

QUESTIONS TO CONSIDER REGARDING THE REQUEST FOR COMMENTS
(NCUA Specifically Requests Comments on the Following Issues)

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
Lilly Thomas • Assistant General Counsel • (202) 508-6733 • lthomas@cuna.com
Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com