ARLINGTON, Va. — NAFCU submitted a letter to NCUA recently in response to the agency's request for comment on the interim final rule encompassing share insurance appeals and the NCUA Board's enforcement authority.

NAFCU President/CEO Fred Becker notes that the interim rule changes NCUA's regulations on judicial review to go to the federal district court where the credit union is principally located; broadens the board's authority to take enforcement actions for violations on conditions imposed on any application, notice or other request; and clarifies the board's authority to issue orders against institution-affiliated parties "regardless of whether they remain institution-affiliated parties of a credit union when the Order is considered or issued."

NAFCU generally supported the interim rule with some modifications. Becker asked that NCUA clarify that insurance appeals pending prior to the effective date of the regulatory relief act are not covered under the new rule. He added that, on the portion concerning institution-affiliated parties, NCUA should consider the length of time a party has been dissociated from the credit union before taking enforcement action.