A few weeks ago, I wrote a blog post on how to write an effective comment letter. With the sheer volume of proposed rules and regulations, it is imperative for credit unions to use this tool to express their opinions and concerns to the regulators. One of the tips from the NCUA that I included in the last post was to suggest alternatives to the proposed rules – however, as several credit unions have heard from the regulators themselves, it is important to include data to back up your arguments as well.
The regulators issuing these proposed rules (NCUA, NACHA, CFPB, etc.) encourage and appreciate any data that can be included, and say it can add weight to your comments. Data could include several things, one of the most important being the cost of compliance – the dollars required to implement new technology, staff time for implementation and training, etc. Along with the other tips – do your research, consider unintended consequences, state your position clearly – data can move your comment letter to the top of the pile and ensure that other alternatives are considered.
If you would like to put these writing tips into action, there is still time to comment on the Risk-Based Capital Proposal, which has a deadline of May 28, 2014.