The National Credit Union Administration (NCUA) Board is requesting comment on whether the sale of secondary and supplemental capital should be limited to only institutional investors, include accredited investor, or allow for anyone to purchase.

I do not believe that the NCUA Board should allow anyone to purchase secondary or supplemental capital.

Many people lack financial sophistication. For people lacking financial sophistication, this product would not be suitable.

NCUA should either require credit unions issuing alternative capital to comply with the Security and Exchange Commission’s Regulation D or issue regulations comparable to Regulation D.

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