WASHINGTON – CUNA recently submitted a comment letter to NCUA regarding its request for comment under the Economic Growth and Regulatory Paperwork Reduction Act. The agency requested comments on the rules addressing: directors, officers and employees; liquidation; and NCUA procedures regarding adjudication proceedings. CUNA suggested that NCUA's rule governing benefits for employees of federal credit unions could be modified to allow a federal credit union investing to fund an employee benefit plan to purchase an investment that would otherwise be impermissible if "the FCU is acting pursuant to its authority to provide retirement benefits to employees," CUNA Senior Regulatory Counsel Catherine Orr wrote. Additionally, an oversight in NCUA's regs prevents credit unions from offering the same interest rate discounts to CEOs-that also serve on the credit union's board – as it does for other employees. CUNA's Orr asked that this be revised. "If NCUA believes there would be a conflict of interest, the agency could seek comments on whether the rule should require the CEO to recuse himself/herself from any board discussions of employee interest rate discounts," she added. While CUNA generally supports NCUA's current proposed regulation on fidelity bonds and insurance coverage, the trade association reiterated that it recommends that NCUA use the same net worth standards from Prompt Corrective Action to qualify for the higher deductible. CUNA also asked for a waiver process for minimum bond coverage.