NAFCU Letter to NCUA on its Request for Outside Legal Counsel Forms

May 9, 2013

Tracy Crews

National Credit Union Administration

1775 Duke Street

Alexandria, VA 22314-3428

RE: Request for Comment Regarding Prospective Outside Legal Counsel Forms

Dear Ms. Crews:

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 Association’s (NCUA or Agency) Request for Comment on the two forms developed to collect information from prospective outside legal counsel.

We believe that it is incumbent on the NCUA, as stewards of the money it receives from federally-insured credit unions and their members, that every cent it collects is administered with the utmost diligence and respect to credit unions and their members. That includes any money spent on outside legal counsel by the Agency. To that end, it is imperative that NCUA implement an efficient process for choosing outside counsel that puts an emphasis on cost effectiveness.

It is imperative that NCUA stays true to its commitment to transparency and releases the information it collects from prospective outside counsel. The first of the two forms developed to collect information from prospective outside counsel includes an estimate of legal fees, costs, and expenses that outside counsel would expect to invoice with respect to a particular legal matter. NAFCU strongly urges that any information collected become available in the most transparent way possible to credit unions and members of the public.

NAFCU appreciates the opportunity to share our comments. Should you have any questions or require additional information please call me at (703) 842-2212.


PJ Hoffman

Regulatory Affairs Counsel

cc: OMB, Desk Officer for the NCUA

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