Several new concerns have been raised about the NCUA's proposal to regulate CUSOs, including whether the regulator took the time to think through its plan.

In late July, the regulator 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.

"[There] are a number of terms in the proposed rule that give the impression that it has not been completely analyzed as to its impact and are in need of significant clarification," wrote Jack Antonini, president/CEO of the National Association of Credit Union Service Organizations in its Aug. 4 comment letter to the NCUA.

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