The 40 or so comment letters filed about the NCUA's methodology for determining the Overhead Transfer Rate was a healthy total of comment letters.

However, what was overwhelming about the OTR letters filed is the consistency of the messages they contained. The first message: Action must be taken by NCUA to correct a flawed system of determining how the NCUA operating budget is funded from the NCUSIF.

The letters filed have come from a broad cross section of the credit union movement. Both national trade associations have weighed in, along with state trade groups (from north to south, and east to west), state regulators, state credit unions, individuals and other organizations.

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