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ARLINGTON, Va.-Small contingents from NAFCU, CUNA and Navy Federal Credit Union attended a Department of Defense-sponsored public forum to solicit public comments on the re-write of DoD Directive 1344.7, which covers personal commercial solicitation on DoD installations. NAFCU President and CEO Fred Becker spoke during the forum on NAFCU’s position on the rule. All three organizations also submitted official comment letters on the matter. First of all, Becker emphasized that NAFCU supported the current rule regarding on-base commercial solicitation. He suggested that April guidance from a DoD undersecretary for personnel and readiness regarding financial education programs be included. CUNA’s official comment letter concurred with this assessment. Additionally, Becker said the right of on-base financial institutions to provide exclusive on-base services should be recognized in the revised directive. CUNA Associate General Counsel Mary Dunn and Senior Regulatory Counsel Catherine Orr attended the meeting and authored the trade association’s official comment letter on the matter. CUNA suggested that the directive “curtail” but not prohibit multi-service financial services companies from cross-marketing services that are also provided by credit unions. All three-CUNA, NAFCU and Navy Federal-said that DoD should recognize credit unions’ CUSOs similar to the way it recognizes banks and their bank affiliates. CUNA specifically recommended a new provision permitting financial institutions to offer life insurance, securities and other financial services directly or through subsidiaries, including CUSOs. Similarly, Navy Federal President and CEO Brian McDonnell advocated that DoD allow on-base credit unions and banks to provide the same services as other credit unions under applicable state and federal laws. NAFCU also asked the directive should include procedures for compliance concerns for on-base financial institutions. Finally, Becker said credit unions, banks and nonprofit military associations should be consulted on how the Military Departments develop and distribute information and programs regarding the conduct of personal commercial affairs. [email protected]

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