In taking steps to provide federal credit unions with derivatives authority as an additional tool to manage interest rate risk on the balance sheet, the NCUA demonstrated flexible thinking in evaluating its rules. That is to be commended. 

However, since the NCUA proposed changes to its derivatives regulation at its May 2013 board meeting, we at NASCUS have noticed confusion within the credit union system about the nature of the proposal. 

Some within the movement have the misperception that NCUA's proposed rule represents the creation of a new authority for all federally insured credit unions. 

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