April 21, 2011, Alexandria, Va. -- National Credit Union Administration (NCUA) Board Chairman Debbie Matz has posted a video on the agency’s website to provide tips for writing effective comment letters. Earlier today, the NCUA Board voted to make significant changes to its final rule on corporate credit unions based on 227 comment letters. Effective comment letters can and do change the rules that NCUA issues.
“In crafting new rules and rewriting existing ones, NCUA recognizes the need to adopt sensible regulations,” Chairman Matz says in the video. “Our goal is to impose the least possible burden on credit unions – especially smaller credit unions. If credit unions want a voice in the regulatory process, comment letters on a proposed rule are an important way to influence the content of the final rule. Comment letters also assist us in fine-tuning and improving regulatory proposals. So,comments really do matter.”
Below are Matz’s four tips:
- Read Proposed Rules and Other Comments – Visit www.ncua.gov to find information about each NCUA proposed rule and the deadline for comments. (Click Comment on a Proposed Regulation.) Prospective commenters can also use the NCUA website to view already submitted comment letters written by other stakeholders.
- Decide Whether You Support or Oppose – Consider whether to support or oppose each provision of a proposed rule. Commenters may choose to support certain provisions and oppose others, or choose to support or oppose the entire proposal.
- Consider Unintended Consequences – Read the Preamble of each proposed rule to understand NCUA’s intent. Think about changes that credit unions might have to implement in order to comply with the proposal. Then write to NCUA about any unintended consequences the rule might create.
- Propose Alternative Solutions – Commenters who oppose a proposed rule, whether in whole or in part, are encouraged to propose reasonable alternatives. NCUA is open-minded about workable solutions consistent with sound public policy.
Matz concludes, “The federal rulemaking process is often about striking the fairest possible balance – between the requirements of the law, our mission to protect safety and soundness, and our effort to minimize any adverse impact on credit unions. So, I hope you view the comment letter process as an opportunity to proactively shape your credit union’s future.”
To view the five-minute video, click here
NCUA is the independent federal agency created by
the U.S. Congress to regulate, charter and supervise
federal credit unions. With the backing of the full
faith and credit of the U.S. Government, NCUA
operates and manages the National Credit Union Share
Insurance Fund, insuring the deposits of more than 95
million account holders in all federal credit
unions and the overwhelming majority of
state-chartered credit unions.