Credit union trade groups are in agreement when it comes to the NCUA's derivatives proposal. Unfortunately, the responses aren't pretty.

"There are so many costly restrictions that credit unions that otherwise should be eligible to invest in derivatives won't be able to do so," said Mary Dunn, CUNA senior vice president and deputy general counsel. "The proposal's goal is laudatory and commendable, but the specifics of it will work to defeat its purpose."

Dunn's July 29 letter endorsed an independent assessment by ALM First, a Dallas-based financial consulting firm, which exposes serious flaws in the NCUA's financial analysis.

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