So the NCUA or Federal Reserve has issued a proposed rule that you detest. What to do?
Hold your fire and be rational.
That’s the advice of some of the regulatory experts at CUNA and NAFCU who write many of those letters and often talk to credit union executives about what to say in their correspondence.
"Keep your emotion out of it. Don’t argue with the goals, but focus on why you disagree with the way the agency wants to reach the particular goal," said CUNA General Counsel Eric Richard.
He added that agency lawyers take into account fact-based evidence and that should be the focus of letters.
NAFCU General Counsel Carrie Hunt advises letter writers not to focus on the big picture.
"Letters are most effective when they focus on the specific implications for and costs to their credit union," she noted. "Don’t write a general letter, that’s going to be the focus of the letters that I write."
Neither Richard nor Hunt would cite examples of specific letters that they felt weren’t effective at getting the message across.
NCUA officials declined requests to discuss what kinds of comment letters they find most helpful when making their decisions.
