RE: Comments on Requirements for Insurance; NCUSIF Equity Distributions

COMMENT LETTER TEMPLATE

National Credit Union Administration Secretary of the Board 1775 Duke St. Alexandria, VA 22314

Dear Mr. Gerald Poliquin,

Introductory paragraph: I am writing on behalf of [your credit union name], which serves [your field of membership]. We have [number] members and [dollar amount] in assets. [Your credit union name] appreciates the opportunity to provide comments to the National Credit Union Administration (NCUA) on its proposed rule regarding the calculation of equity distributions from the National Credit Union Share Insurance Fund (NCUSIF), including a temporary provision to govern NCUSIF equity distributions resulting from the Corporate System Resolution Program.

Letter Body: Regular NCUSIF Equity Distributions: For regular NCUSIF equity distributions (not resulting from the Corporate System Resolution Program), the Board is considering two methods for calculating a FICU’s proportionate share of an NCUSIF equity distribution: a four quarter average of insured shares method, or a year-end insured share balances method.

Which method do you favor, and why?

What challenges exist with your preferred method, and how can they be addressed?

If the Board were to adopt an average insured balances method, is the last four quarters appropriate, or should there be a longer look-back period (e.g., 18 or 24 months)?

Conversion From, or Termination of, Federal Share Insurance

Should the NCUA prohibit NCUSIF equity distributions to FICUs that terminate federal share insurance coverage during the calendar year? Why, or why not?

Do you agree with NCUA’s proposal to treat a liquidated FICU’s insurance termination date as the date the FICU enters liquidation?

Corporate Resolution Program – NCUSIF Equity Distributions: As proposed, NCUSIF equity distributions resulting from the Corporate System Resolution Program will be based on the amount of assessments actually paid by each FICU, based on a last-in, last-out (LILO) calculation. The Board also seeks comments on other methods, including a first-in, first-out (FIFO) calculation, as well as whether the four quarter average of insured shares method or the year-end insured share balance method should apply. With respect to the last-in, last-out (LILO) and first-in, first-out (FIFO) methods, which method do you prefer for repaying the assessments? Why?

Should the Board contemplate a calculation that considers a FICU’s insured shares balance? Why or why not?

Do you agree with NCUA’s proposal that a liquidated FICU with an open liquidation estate or a closed liquidation estate still within its applicable look-back period will receive a NCUSIF equity distribution related to the Corporate System Resolution Program? Why, or why not?

Federal Share Insurance Premiums

Should the Board calculate federal share insurance premiums as consistently as possible with a final rule on how each FICU’s proportionate share of an NCUSIF equity distribution is calculated?

Do you have other recommendations regarding the assessment and collection of federal share insurance premiums that would provide greater fairness, transparency, and predictability? Summary of your position:

[Write the summary of your position here.]

Closing paragraph: Thank you for the opportunity to comment on this proposed rule and for considering our views on the calculation of equity distributions from the NCUSIF, including a temporary provision to govern NCUSIF equity distributions resulting from the Corporate System Resolution Program.

Sincerely, First, Last Name Title Credit Union Name (include credit union address and contact information, if desired)

CC: New Jersey Credit Union League