October 21, 2013
Gerard Poliquin
Secretary of the Board
National Credit Union Administration
1775 Duke Street
Alexandria, VA 22314-3428
RE: Charitable Donation Accounts
Dear Mr. Poliquin:
On behalf of the National Association of Federal Credit Unions (NAFCU), the only trade association that exclusively represents federal credit unions, I am writing to you regarding the National Credit Union Administration’s (NCUA) request for comment on the proposed rule regarding charitable donation accounts (CDA). NAFCU generally supports this rule and we think this is a great first step towards increased investment authority for credit unions.
Because of the fundamental make up of different fields of membership, credit unions are tied to their communities like no other types of financial institutions. Many credit unions have been very successful in assisting others in their community and this rule allows credit unions to have the flexibility to get higher returns for their charitable investments. Credit unions’ understand the needs of their members and this new tool give credit unions a better way to make a difference in the towns and cities where their members live.
This proposed rule is a great first step that will benefit credit unions and their members. NAFCU urges the NCUA not to stop there. Over the past few years, the NCUA signaled that it is reviewing credit union investment powers such as the recent proposed rule regarding derivatives. We believe the NCUA should also revise other sections of Part 703 to enable credit unions more options to serve their members.
With that in mind, NAFCU believes the NCUA should remove from the list of prohibited activities the ability to purchase Mortgage Servicing Rights (MSRs). In particular, at the very least, a federally-insured credit union should not be prohibited from purchasing MSRs from other credit unions. We understand that the NCUA has also considered expanding credit unions investment authority into securitization that credit unions may sell to public or private markets. NAFCU urges the NCUA to continue expanding investment authority for credit unions so that they may have the tools available to be serve the needs of their members.
Thank you for your continued commitment to listen to feedback. Should you have any questions or would like to discuss these issues further, please feel free to contact me at PJHoffman@nafcu.org or (703) 842-2212.
Sincerely,
PJ Hoffman
Regulatory Affairs Counsel