Awaiting The "Second Coming" Of The RBC: Crocktoberfest...

From The NCUA Report
(April 2011):

"Four Tips For Effective Comment Letters"

1)  "Does NCUA really read all comment letters on every proposed rule? Yes!"

2)  "Do comment letters really lead to rule changes? Yes!"

3)  "I assure you: NCUA is open-minded about workable solutions consistent with sound public policy."

4)  "Before we finalize any rule, we then deliberate internally. We consider changes based on the comments. And we talk through different scenarios about how a revised rule might play out over time.... we take it very seriously. "

"We look forward to reading your comment letters."

 

We, We, We ?

Four Tips For NCUA

(October, 2014)

1)  Consider asking for input and opinions - in an open, transparent, "all stakeholders at the table" dialogue -  before you write the proposed rule.  Despite what you may believe, most of your "stakeholders" are not stupid, may actually know something about the operation of a credit union, are equally concerned with strong/fair regulation, and also ..."take it very seriously."

2)  Stop looking for new Credit Union rule ideas by "dumpster-diving" over at the FDIC - despite those past, copycat  "Suze Orman Teeth and Jacket" ads: 

"There is a difference".

3)  Try to at least feign humility - the "Royal WE" is so very unattractive.

4)  And, note the growing signs that many of your "stakeholders" think that the current rule-making process at NCUA discourages participation, suffers from a lack of credibility, and is frequently viewed as just a ....

RBC !!! **


** Risk-Based Crock !!!