WASHINGTON-CUNA and NAFCU recently submitted comments to Senator Mike Crapo (R-Idaho), who is in charge of drafting regulatory relief legislation in the Senate, on the `matrix' of provisions under consideration for the bill that he has circulated. "As you may recall from our testimony before the Senate Banking Committee on June 22, credit unions are the most heavily regulated of all insured financial institutions," CUNA President and CEO Dan Mica wrote in the Sept 15 letter. "Any effort to reduce or eliminate unnecessary paperwork and regulatory obstacles can only help credit unions improve the quality of service their members have come to expect." Both groups stuck with commenting on the aspects of the matrix related to credit unions, leaving the remaining provisions-the bulk of the items under consideration-untouched. CUNA and NAFCU were also careful to point that out. NAFCU President and CEO Fred Becker wrote, "The matrix contains many proposals that do not impact the day-to-day operations of credit unions, and upon which we do not take a position at this time. Accordingly, we will focus our comments on those proposals in the matrix that will have a direct impact on credit unions and for which it is therefore important that we comment on at this juncture." CUNA and NAFCU were in support of most of the credit union-related proposals in the matrix. However, both questioned whether NCUA really needed the authority to examine credit union vendors post Y2K. Even NCUA recently wrote in a letter to the Government Accountability Office, "NCUA . has not experienced insurmountable problems associated with the lack of direct authority over third-party vendors." NAFCU cited. Mica also indicated that while CUNA feels the credit union charter is best for consumers, when making the decision to switch to a mutual savings bank, members should be properly informed when exercising that right. Permitting alternative capital in net worth calculations for Prompt Corrective Action purposes, credit union governance provisions, and expanding business lending authorities for credit unions were also items of which CUNA and NAFCU were supportive. [email protected]

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