Schaefer, whose credit union has $1.1 billion in assets and is based in Winston-Salem, N.C., wrote that more credit unions might participate if the agency answered questions such as why the agency won't allow credit unions to prepay their entire assessment all at once and what additional administrative costs the NCUA might incur.

He also suggested the agency provide a clear review of the corporate credit union stabilization process, including disclosing the terms of the line of credit from the Treasury Department. He also requested the agency disclose projected cash flows that might drive future assessment rates.

Local Government FCU President/CEO Maurice Smith expressed "conditional support" for the program and wrote that he wanted to see the final details. He said the $1.1 billion credit union based in Raleigh, N.C., welcomes "the opportunity to smooth out the impact of the assessments for the ensuing years."

Chevron FCU Vice President and Controller Mitch Dormer wrote that he couldn't make a decision until he sees the Temporary Corporate Credit Union Stabilization Fund's financial statements, so he can understand its borrowing position, the interest rates paid and payment due dates. Dormer's Oakland, Calif.-based credit union has assets of $1.5 billion.

State Employee Credit Union of North Carolina President/CEO Jim Blaine didn't file a comment letter,  but he told Credit Union Times that "I'd feel obligated to make an interest-free loan to my members before I made one to the NCUA. We've had 5,000 state employees laid off and 10,000 to go, and there is a great need there." His Raleigh, North, Carolina-based credit unions has assets of $22 billion.

FAA Credit Union President/CEO Steve Rasmussen said his institution has a "highly favorable" opinion of the plan and might even be willing to prepay three or four years worth of assessments. The Oklahoma City, Okla.-based credit union has assets of $484 million.

Marinette County Employees CU President/CEO Kay Hinkens wrote that her $40 million Marinette, Wis.-based credit union would commit to 25 basis points of prepaid funds if the total minimum were raised from $300 million to $1 billion.

Marshfield Medical Center CU in Marshfield, Wis.,  said it couldn't support the plan as is but suggested several modifications, including paying interest on the loan to the NCUA, raising the minimum total participation from $300 million to $1 billion.

In her comment letter, Carol Adler, the president of the $50.2 million credit union, also requested additional details on the agency's modeling of future costs and an estimate of additional costs to administer the program.

Many of Hinkens' and Adler's comments are the same as those offered in CUNA's comment letter.

CUNA President/CEO Bill Cheney argued in favor of paying interest and wrote that raising the minimum to $1 billion would cause a 13 basis point reduction in the assessment, compared with a 4 basis point reduction if the total were $300 million. This would lessen the negative effects of free riders, he wrote.

NAFCU President/CEO Fred Becker wrote that the agency should eliminate the maximum amount of each credit union's contribution because each credit union "is more than capable of assessing its own liquidity position." He also recommended that the agency shouldn't add a line on Call Reports to indicate the amount a CU has prepaid.