On Monday, August 7, the League submitted a comment letter to the National Credit Union Administration regarding its proposed rule to revise procedures a federal credit union (FCU) must follow in a voluntarily merger with another credit union. The NCUA also requested comments on whether the rule should extend to federally-insured state-chartered credit unions (FISCUs).
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.
Advocating on behalf of credit unions in North and South Carolina, the League outlined reasons why the current rule on financial disclosures of merging credit unions is sufficient, illustrated potential problems with member-to-member communications, and proposed maintaining the current state-adopted merger rules.
"Credit unions value the views of their member-owners and support efforts to ensure they are aware of any changes that could impact the credit union’s safety and soundness," writes League VP Compliance/Regulatory Counsel Jeanne Couchois in the letter. "CCUL concurs with NCUA that transparency, clarity, and adequate information are essential prerequisites in a voluntary merger. How we get there is the issue."