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ARLINGTON, Va. – NASCUS responded to the NCUA’s request for comments on the agency’s 2005 Regulatory Review and addressed its comments on the organizational structure of NCUA’s rules and regulations. In its letter written by VP Regulatory Affairs Brian Knight and filed Aug. 1, NASCUS suggested that NCUA combine within Part 741 all rules applying to federally insured CUs, rather than incorporate rules by reference as is presently done. In addition, NASCUS’ letter states that, “In order to understand insurance rules, credit unions should be required to review Part 741 only and not be forced to search throughout NCUA’s rules for referenced provisions.” “Such a consolidation of rules would ease compliance burdens on smaller credit unions and clarify misunderstandings concerning which rules and which parts of rules apply,” Knight wrote He cited by example Part 715 which he stated “only partially applies to state-chartered federally insured credit unions, however NASCUS often receives questions from state-chartered credit unions as to non-applying provisions of the rule.”

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