November 26, 2012
Mary Rupp
Secretary of the Board
National Credit Union Administration
1775 Duke Street
Alexandria, VA 22314–3428
RE: Low-Income Credit Union; Acceptance of Designation
Dear Ms. Rupp:
On behalf of the National Association of Federal Credit Unions (NAFCU), the only trade association that exclusively represents federal credit unions, I am writing you regarding the National Credit Union Administration’s (NCUA) proposed rule to extend the amount of time that a credit union has to accept a designation as a low-income credit union (LICU). See 77 Fed. Reg. 65319 (October 25, 2012).
NAFCU appreciates NCUA’s initiative in this rulemaking. As the agency recognizes, credit unions should be provided adequate time to consider whether to accept a LICU designation in order for both management and boards to fully examine the utility of the designation and any possible drawbacks. Thus, the proposal to increase the time that credit unions have to accept from thirty days to ninety days is welcome.
NAFCU would like this opportunity to encourage the NCUA to review its regulations and make any and all changes, including seemingly small changes, like the LICU change, which can benefit credit unions.
NAFCU appreciates the opportunity to share our thoughts on the proposed rule. Should you have any questions or require additional information please call me at (703) 842-2268.
Sincerely,
Tessema Tefferi
Regulatory Affairs Counsel