CUNA has serious concerns with several key parts of the proposed corporate credit union rule, including a limit on the number of corporates a credit union can belong to and encouraging a fee to entities not federally insured.

In the association's comment letter filed late Monday with the NCUA, it wrote that "only when an agency is directed by statute or imminent, overarching safety and soundness concerns should it impose regulatory limitations on activities that should otherwise be determined by the marketplace."

CUNA also took issue with the NCUA proposal under which expenses for NCUA Corporate Credit Union Stabilization Fund expenses would be shared among all members of corporate credit unions, including all federally insured credit unions and nonfederally insured credit unions.