The National Association of Credit Union Service Organizations has raised several new questions about the NCUA's proposed new CUSO regulations.

In late July, the agency proposed a rule that would require all CUSOs to file financial reports directly with the NCUA and the appropriate state supervisory authority. The board also proposed limiting federally insured, state-chartered credit unions' aggregate cash outlays to a CUSO.

In a comment letter today, NACUSO questioned the definition of a "subsidiary." Under NCUA's proposal, all requirements in the CUSO rule would also apply to subsidiary CUSOs.

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