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John F. Kozlowski,
General Counsel
The Ohio Credit
Union League's general counsel has recently filed the following
comments on regulatory and legislative matters.
Proposed revision to Rule on Insured Credit Unions converting to
Mutual Savings Banks
The League has filed comments in response to NCUA’s request for
comments on its regulation regarding conversion of insured
credit unions to mutual savings banks. In the letter, the League
asks NCUA to clarify some of the language in the proposal, but
agrees with the intent of the proposal, which is to make it
easier for members to understand the conversion process and the
effects and costs of a conversion to a stock institution.
(Oct. 2004)
Proposed Revision To NCUA’s Rule
on Credit Union Conversions to Thrifts
Comments on
NCUA’s proposal to update the rule regarding conversion of
insured credit unions to mutual savings banks. This proposal,
seeking to accomplish full disclosure, would require a
converting credit union to provide additional information in the
notice to members of its intent to convert.
(Dec. 1, 2003)
Proposed Revision To NCUA’s Loan Participation Rule
Pertains to a proposal amending the agency’s loan
participation rule. This proposed loan participation rule
revision is unrelated to the proposed changes in the member
business loan (MBL) rule that would allow credit unions to
exclude loan participations from the 12.25% asset limit on MBLs.
(Sept. 26, 2003)
ACH Returns Issues (Invalid SEC Codes & Fraudulent)
Note: These comments appear as a
combined document with the comments below)
Regarding the ability to return certain types of
automated clearing house (ACH) entries, specifically those that
the receiving depository institution (RDFI) believes contain a
Standard Entry Class (SEC) Code that is not valid for that
account type or that the RDFI believes may be fraudulent.
(Sept. 26, 2003)
ACH Returns – ACH Operator Requirements
Note: These comments appear as a
combined document with the comments above)
Regarding modification to the current provisions of the NACHA
Operating Rules relating to (1) Remove an ACH Operator edit
related to the Original Receiving DFI (Depository Financial
Institution) Identification Field within the addenda records of
the dishonored return and contested dishonored return entries
that is inconsistent with the definition of the field, and (2)
Require ACH Operators to settle return entries no earlier than
the effective entry date in the original Company/Batch Header
Record. (Sept. 26,
2003)
Matricula identification/USA PATRIOT Act
The Ohio Credit Union League opposes revisions to the U.S.
Treasury's final USA Patriot Act that would prohibit financial
institutions from accepting Matricula identification.
(July 31, 2003)
Read
the full comments.
Recordkeeping (photocopies of I.D. documentation)/USA PATRIOT
Act
The Ohio Credit Union League opposes revisions to the U.S.
Treasury's final USA Patriot Act that would require financial
institutions to photocopy identification records. (July
31, 2003) --
Read
the full comments.
Comments to NACHA on ACH arbitration rule changes
(May 27,
2003)
Department of Commerce
regarding the current exception in the Electronic Signatures in
Global and National Commerce Act (E-SIGN Act) as it
applies to Articles 3 & 4 of the Uniform Commercial Code, which
are provisions that relate to processing checks.
(March
6, 2003) --
Read
the full comments.
The Ohio League has
filed comments with the Federal Reserve on
The Federal
Reserve Board’s
proposed
revision to the official staff commentary that accompanies
Regulation Z, the Truth in Lending Act (TILA).
(Jan. 29, 2003) --
Read
the full comments.
The Ohio League has filed
comments with the U.S. Dept. of Commerce the National
Telecommunications & Information Administration’s E-Sign Act,
which preserves the legal effect, validity, and enforceability
of signatures and contracts relating to electronic transactions
and electronic signatures used in the formation of electronic
contracts.
(Jan. 13, 2003) --
Read
the full comments.
The Ohio League has filed
comments with the NCUA
regarding
the Treasury’s Financial Crimes Enforcement Network (FinCEN),
and proposed revisions to the Suspicious Activity Report
(SAR) form.
(Jan. 3, 2003) --
Read
the full comments.
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