Short Comment Period, Short Responses

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In the briefest of public comment periods, credit union representatives told NCUA last week they support efforts to illustrate their member service to Congress, but questioned the methodology of the pilot data collection program.

The handful of credit unions submitting comments in what amounted to a three-day comment period all agreed that cooperation on their part will take much longer than the one hour NCUA has projected.

The comments were submitted during an unprecedented five-day comment period, including a two-day weekend, and then only after the White House Office of Management and Budget insisted NCUA could not proceed with the data collection program before complying with proper administrative procedures, which include collecting public comments. Typically NCUA submits proposals for comment periods as long as 90 days, or as short as 30 days when they seek to implement a policy or rule expeditiously.

Most commenters wondered how NCUA will define the term "modest means" as it seeks to measure credit unions' service to members of modest means. Others said the data on income of borrowers is not readily available and will require some work to produce. Other credit unions suggested that NCUA try to expand the reach of the data in order to give Congress and other potential audiences of the data a greater picture of how different charter types may comply with service to the underserved.

"As you know," wrote Lisa Schlehuber, president of Eli Lilly FCU, "the origination of credit unions was driven by companies wanting to provide financial opportunities to the working men and women of America. Some of us remain committed to that same goal and are concerned that extensive focus on purely the members of modest means exclude the significant good provided to all others."

John Tippetts, president of American Airlines FCU, suggested that NCUA broaden its data collection from the 481 targeted credit unions to include all credit unions authorized to serve underserved areas. Tippetts also said when interpreting the data collected NCUA ought to consider recent charter changes by credit unions.

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