Today, Credit Union National Association sent this comment letter in response to the NCUA’s proposed suspension and debarment procedures. CUNA supports the agency’s decision to take administrative action to address due process in the agency’s procurement process.
“CUNA agrees with the agency that for the purposes of a liquidation or conservatorship of an undercapitalized or failing credit union, suspension and debarment procedures need not be applied to legal services contracts, whether provided on behalf of NCUA as an agency or the NCUA board as conservator or liquidating agent,” the letter reads. “CUNA does not believe that the proposed rule regarding suspension and debarment processes should materially restrict the board’s statutory contracting rights as conservator or liquidating agent.”
CUNA believes the provisions within the proposal that provides contractors with an option for judicial review provides sufficient remedy.