On March 31, 2008, our office responded to the NCUA's request for comments concerning its Advance Notice of Proposed Rulemaking on Rules 708a and 708b (ANPR), which addresses the responsibilities and duties of credit union directors in the contexts of mergers and conversions. Our comments are provided from the perspective of attorneys representing more than 350 federal and state chartered credit unions.
We applaud the NCUA in its efforts to address the apparent lack of standards for federal credit union directors, and have suggested content for possible rules in this area. We believe clear and concise rulemaking in this area could provide much-needed guidance to federal credit union directors. Additionally, we applaud the NCUA's desire to address the issue of hostile merger offers, and have suggested the NCUA promulgate rules in this area to protect members from coercive offers.
Read the complete comment letter . . . (PDF Download - 1.76 MB)
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