Mr. Gerard Poliquin
NCUA, Secretary to the Board
1775 Duke Street
Alexandria, Va. 22314
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| Looks like "snail" may be fastest ! |
Ref: Commenting on Proposed Risk-Based Capital (RBC) Rule
Dear Gerry,
Called you last week and left you a message. Wanted to ask you a question about NCUA's policy governing commenting on proposed rules; but I never heard back from you.
Actually, I tried to call several very important folks at NCUA, but all I found out was that everybody at NCUA has voicemail. Guess you were all out "regulating". Hope it was that; and not that you have "caller ID". (Just kidding!… sorta.)
My question was: "What is NCUA's official policy on posting comment letters in a timely manner?" The reason I ask is that there has started to be a lot of grumbling that NCUA is purposefully delaying the posting of comment letters on the new RBC rule.
I would imagine that's not true, but thought it best to ask. As always, you just can't count on the Post Office delivering those emails to you in a timely fashion. Been a lot of " snow, rain, heat, and gloom of night" out there on the internet of late, so delays can happen! Realize that the law requires you to post the comment letters "as submitted", but could you let us all know what the law means or what you've decided it means, if you know what I mean.
It's kinda important since everybody and his sister is up in arms about the RBC rule and are being urged to send you a comment… or worse!
And, even though the Chair has adamantly refused to extend the comment period, we all know she's listening and already knows what's best; so getting those comment letters posted quickly really can't hurt, can it?
If you're real busy regulating; you could just drop me a comment on this blog, if you like. Hope your finger's doing better.
Sincerely,
Jim Blaine
2 comments:
I know based on personal experience that the agency is not there to answer to the people that are working at the places (Credit Unions) that are footing the bill for their bloated bureaucracy. You can email the various top staff at the NCUA and you will never get a response. When all else fails you can then email the Ombudsman, which is a most imaginative way to waste more CU money by creating the illusion that there is someone that can actually help to resolve an issue. The Ombudsman may email you back, however, the message will not come from any specific human, it will be a Wizard of Oz like behind the curtain response which will in effect tell you what the current rules are and that you should be following them whether they make sense or not – because they are the rules.
Good luck getting changes to anything once it is put in place, including the proposed risk based capital regulation. This agency that we are dealing is set up so that its staff, with the exception of the examiners on the front line, does not have to deal in any way with any human at a credit union.
It is one thing to use voice mail as a means of getting a message when you are in a truly important meeting or busy trying to justify a bad idea, but to not return the call timely is just the act of a coward!
I bet many credit unions have a policy about returning all calls timely!
Voice mail should not be used has a shield to avoid responsibility.
Jim: you should post the time and the date of their return call and the time it took from your call for them to return. Tick, Tick, Tick!
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