Restricting credit unions to belonging to one corporate credit union is "contrary to the principle that member-owner natural person credit unions determine the future of their corporates and the corporate system as a whole," NAFCU wrote in its comment letter to the NCUA.
NAFCU President/CEO Fred Becker also wrote in a letter filed today that the provision of the proposed rule could eventually result in a dilution of quality in corporate products and services."
He also expressed concern about the agency's proposed mechanism for getting non federally insured credit unions and non credit unions to pay for the rescue of the corporates. The agency proposes encouraging non-federally insured members to pay a fee that would go to the Temporary Corporate Credit Union Stabilization Fund.
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Becker wrote that this could cause such entities to "simply choose to abandon the corporate credit union system and thus have no incentive to recapitalize the corporates."
He praised the provision of the proposal that would allow corporate credit unions to assess membership fees but suggested that the agency add a provision requiring the decision to be made by the corporate's membership.
Becker objected to the NCUA's proposal to require that when corporate credit unions publish minutes of their board meetings they include how each board member voted on every issue and mention which members abstained or were absent from the meeting.
Becker wrote that the agency "may be overreaching," and would dissuade qualified people from serving on boards and each board should determine whether to record board votes.
He praised the proposed provision mandating that corporate credit unions establish an enterprise risk management committee that must include at least one independent expert with no family or material business or professional relationship to the corporate.
However, he asked the agency if that expert can be outsourced and also if the agency could define "material business or professional relationship."
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