Ms. Becky Baker
Secretary of the Board
National Credit Union Association
1775 Duke Street
Alexandria, VA 22314-3426

Dear Ms. Baker:

I am pleased to respond to the NCUA's request for comments on regulations under the Economic Growth and Regulatory Paperwork Reduction Act of 1996.

President/CEO of NAFCU, Fred Becker, has already presented you with a detailed discussion of these regulations and has shared NAFCU's stance on each of the topics. Having carefully studied Mr. Becker's response, I am in total agreement with him on all issues. I believe that the arguments he has put forward will result in a stronger and more efficient credit union industry that is better prepared to meet the needs of our growing membership.

I am particularly pleased to see the regulations address several issues that are of special importance to me.

• Our credit union recently went through the conversion process to community charter status. While the Board and management are pleased with the strategic decision we made to convert, it has been a hard experience to sever our ties with some very fine "select groups" that we can no longer serve as a result of the charter change. Many of these SGs are going to find it difficult to match the quality of financial services in their area that we were able to offer them for many years. Credit unions going into the community conversion process should be allowed to maintain important financial services for SGs that are located outside the community.

• I am also very much in favor of extending the maximum loan term limitation from 12 years to 15 years or longer. For example, there are many opportunities for boat or recreational vehicle lending that clearly merit this longer term. These are higher ticket items that require a longer pay down period for them to be affordable for credit qualified members.

• Credit unions both small and large are constantly looking for ways to serve their existing members better and bring new members into the institution. I strongly support any regulatory initiative that would eliminate the "reasonable proximity" requirement for placement of new ATMs to serve members that are just beyond the normal range of efficient traditional branch banking service.

It is always rewarding to have the opportunity to comment on important issues that will impact the future success of our industry. I endorse Fred Becker's words on behalf of NAFCU and look forward to our regulators emerging with a package that will continue to strengthen the work and influence of our credit unions at all levels of society.

Don W. Lewis
President/CEO
Aberdeen Proving Ground Federal Credit Union
Aberdeen, MD