WASHINGTON (2/6/09)—Credits unions are encouraged to share all their concerns and questions regarding a possible restructuring of the corporate credit union system, the Credit Union National Association (CUNA) reminded Thursday. In a CUNA Comment Call posted Thursday, CUNA noted that the National Credit Union Administration (NCUA) asks many questions on very narrow issues in its advance notice of proposed rulemaking (ANPR) regarding the structure and operations of corporate credit unions. However, CUNA advised, credit unions should not feel required to address each question individually or to limit their comments to just the issues that NCUA has presented. “Any concerns or suggestions regarding the corporate credit union system in general are welcomed,” CUNA Deputy General Counsel Mary Dunn wrote. The ANPR was prompted, Dunn explained, by concerns over the recent decrease in the value of corporates’ investment portfolios and the virtual market freeze-up which has prevented the trading of certain investment securities. The NCUA, she noted, believes these challenges have undermined the stability of the corporate credit union system. The NCUA ANPR asks series of questions on a broad range of topics, such as:
* The role of corporates in the credit union system; * Appropriate capital requirements for corporates; * Corporate investment authority and limits; * Asset liability management; and * Corporate governance.
CUNA’s Comment Call asked credit unions to send comments on the ANPR as soon as possible. They are due to the NCUA April 6. Dunn said CUNA’s comment letter to NCUA is being developed in conjunction with its Corporate Credit Union Task Force. The task force was formed late last year to address potential concerns with the corporates and is comprised of individuals from various natural person credit unions. A meeting has been scheduled here next week. Use the resource link below to read all the NCUA’s ANPR questions and access the CUNA Comment Call.