NCUA Provides Guidance on How to Write a Comment Letter
April 14, 2011
April 14, 2011
National Credit Union Administration (NCUA) Chairman Debbie Matz assured credit unions in the agency’s monthly newsletter that the NCUA does in fact read—and sometimes heed—comments on regulatory proposals. She also shared tips on what makes a good comment letter.
Matz said the NCUA’s attention to comment letters will be clear at its April 21 open meeting, where “potentially significant changes” to the agency’s proposed rule on corporate credit unions will be unveiled. She said the draft changes are being based on a review of the 227 letters sent to the agency by interested parties.
In fact, comment letters are so important that your Association employs a full time regulatory advocate, Jaycee Winn, who works directly with the agencies to influence rulemaking. She is happy to assist credit unions in writing their own comment letters or in providing feedback to the NWCUA for inclusion in its comment letter.
Chairman Matz provided four tips for credit unions writing their own comment letters:
- Do Your Research: Visit http://www.ncua.gov/ to find information about each NCUA proposed rule and the deadline for comments. Use the agency website to view already submitted comment letters written by other stakeholders.
- Consider Unintended Consequences: Read the preamble of each proposed rule to understand NCUA’s intent. Inform the NCUA about changes that credit unions might have to implement in order to comply with the proposal, and also about any unintended consequences the proposal might generate.
- State Your Position Clearly: While a credit union might support or oppose some proposals in their entireties, letter writers are also encouraged to go on record when they support certain provisions and oppose others.
- Suggest Alternatives: When opposing a proposed rule in whole or in part, let the agency know why. Matz says the most effective comment letters propose reasonable alternatives. “NCUA is open-minded about workable solutions consistent with sound public policy,” she assured.
Matz described the federal rulemaking process as one that seeks to strike “the fairest possible balance” between requirements of applicable law, the agency’s mission to protect safety and soundness, and its effort to minimize any adverse impact on credit unions.
“We look forward to reading your comment letters,” Matz concluded in her newsletter column.
Questions? Contact NWCUA Director of Regulatory Affairs Jaycee Winn: 503.350.2209, email@example.com