Becky Baker
Secretary of the Board
National Credit Union Administration
1775 Duke Street
Alexandria, VA 22341-3428
Subject: Request for Comment: Economic Growth and
Regulatory Paperwork Reduction Act of 1996
Dear Ms. Baker:
We have reviewed the subject, and respectfully offer
our comments for NCUA consideration. The NCUA Board and
staff are commended for their continued efforts to
provide regulatory flexibility where appropriate.
Field of Membership/Charting (Part 701.1; 1RPS
03-1) - Clearly, the NCUA continues to attempt to
provide as much flexibility as allowed by law, as credit
unions seek broader FOM options. We encourage and are
confident that NCUA will continue to identify and
implement improved FOM powers in a prudent manner,
consistent with applicable law.
Conversion to a State-charters Credit Union (Part
741.7) - If a Federally insured credit union met all
insurance requirements prior to applying for a state
charter, requiring an application from the credit union
to continue insurance appears to be an unnecessary
regulatory burden, and thusly, a barrier to conversion.
We suggest the requirement for an insurance review be
deleted from this Part.
Member Business Loans (Part 723) - Part 723.15
contains guidance related to reserves for potential
member business loan losses. To assure consistency with
IRPS 02-3, FAS 5, and FAS 114, we suggest that NCUA
review this Part and make any appropriate changes.
Designation of Loan-Income Status; Receipt of
Secondary Capital Accounts by Low-Income Designated
Credit Unions (Part 701.23) - We continue to support
the use of secondary capital, and encourage the NCUA to
develop provisions for the use of secondary capital in
all credit unions.
We strongly support efforts to reduce credit unions'
regulatory burden wherever possible, while continuing to
assure the safety and soundness of America's credit
unions. Thank you for considering the comments of
Security Service Federal Credit Union. If you have any
questions or require clarification, Chief of Staff
Howard Baker or I am available at your convenience at
(210) 476-4550.
Sincerely
Max Giovannini
Chairman of the Board
Security Service Federal Credit Union
San Antonio, TX
