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August 19, 2016
NAFCU suggests fixes to CDRLF amendments
NAFCU Senior Regulatory Affairs Counsel Michael Emancipator on Friday expressed the association's support for NCUA's proposed amendments to the Community Development Revolving Loan Fund rule and made suggestions on how to improve implementation.
NCUA proposed technical amendments to the CDRLF rule in June; comments are due to the agency today. NCUA said the amendments would "make the rule more succinct and update it to improve its transparency, organization, and ease of use by credit unions."
Emancipator recommended NCUA reevaluate the removal of the definition of "fund" in the amendment and that language be included that explicitly states there is no aggregate funding limit. He also suggested further clarification regarding the state supervisory authority concurrence process for state-chartered credit unions and the appeals process for technical assistance grants.
He thanked NCUA for clarifying what information needs to be reported to the agency and to members, which alleviates some of the reporting burden on credit unions.
NCUA proposed technical amendments to the CDRLF rule in June; comments are due to the agency today. NCUA said the amendments would "make the rule more succinct and update it to improve its transparency, organization, and ease of use by credit unions."
Emancipator recommended NCUA reevaluate the removal of the definition of "fund" in the amendment and that language be included that explicitly states there is no aggregate funding limit. He also suggested further clarification regarding the state supervisory authority concurrence process for state-chartered credit unions and the appeals process for technical assistance grants.
He thanked NCUA for clarifying what information needs to be reported to the agency and to members, which alleviates some of the reporting burden on credit unions.
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