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ALEXANDRIA, Va.-As of deadline, NCUA had received just over 100 comment letters regarding its field of membership proposal. While NCUA Chairman Dennis Dollar did not have an exact number, a fair amount of the comments have come from the banking industry. “We give weight to comments based upon the issues raised and the relevance of the comments, so we will take the bankers’ comments seriously, just as we will take the credit unions’ comments seriously,” Dollar said. While the bankers’ comments-likely to be opposing the broadening credit unions’ FOM authorities-will be taken seriously, “this is not a letter writing turnout contest,” the chairman said. The emphasis is on quality not quantity, Dollar said, and if the banking groups present fresh ideas, instead of the “same time-worn legal arguments” they have already lost in court, they will be considered. Dollar reminded that the board’s ultimate responsibility is to do what is “best for the longterm viability of credit unions.” He added that the issue is not just about access but also about risk management and providing credit unions with greater diversification options. As part of his effort to encourage public comment on the FOM proposal, Dollar recently wrote an opinion piece on the subject in the Jan. 15th issue of Credit Union Times. “This is an important issue. I hope we get an increased number of comments to give us even more perspective as we address field of membership now and in the future,” he said in a recent interview. Other big issues, like the Community Action Plan, drew several hundred comments, and Reg Flex brought in well over 1,000 comment letters. Dollar said it would be impossible to guess how many comment letters on the FOM proposal the agency might receive, but he said it is often the case to receive half the letters in the last week. “I can’t speculate as to why they don’t have more but what I’ve seen.a lot of times when credit unions are pleased with a regulatory proposal, they’re less likely to comment,” NAFCU Director of Regulatory Affairs Gwen Baker explained. NAFCU has not submitted its letter yet, and will probably wait until the last day to get it in, but Baker said it will be generally positive with a few suggestions for additions. To encourage members to comment, NAFCU President and CEO Fred Becker e-mailed all NAFCU members reminding them to comment and included articles in the online and print versions of NAFCU’s Update newsletter. CUNA, also, has not completed its comment letter yet. The trade group has also encouraged members to comment through its Web site. CUNA Associate General Counsel Mary Dunn was unavailable for comment before deadline. Comments are due to the agency by Feb. 3. They can be faxed to (703)518-6319; e-mailed to [email protected]; or mailed to Secretary of the Board Becky Baker, 1775 Duke Street, Alexandria, Va. 22314. [email protected]

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