Mon, Aug 14, 2017
On Monday, August 7, the MD|DC Credit Union Association submitted a comment letter to the NCUA regarding its proposed Voluntary Merger Rule.
The rule would:
- Revise and clarify the contents and format of the member notice;
- Require the merging credit union to disclose all merger-related financial arrangements for covered persons;
- Increase the minimum member notice period; and
- Provide procedures to allow reasonable member-to-member communications regarding the proposed merger.
Based on responses from its member survey, the Association signaled support for the spirit of the proposal -- greater transparency and member awareness -- but expressed serious reservations about some specific provisions, particularly the member-to-member communications section.
MD|DC Credit Union Association CEO John Bratsakis wrote:
“The Association is in support of the NCUA’s intent to bring greater transparency and clarity to the merger process. However, we cannot support the sections that would place undue and unnecessary burdens on the merger process for credit unions. The merger rule should provide a regulatory framework that does not add to the current regulatory burden that credit unions bear in their daily operations, as well as enhance the ability of members to exercise their legitimate rights of cooperative ownership in a commonsense, practical manner.”