Questions for Comment

Please provide feedback to CUNA by answering the following questions.
1. Do you support the process where credit unions are allowed to exceed the 5% fixed assets limit through a FAM program?
2. Would you like to see the waiver option retained as an option for pre-approval of a fixed asset acquisition?
3. NCUA states that it will provide guidance at a later date. Guidance is very important and can make much difference in how the requirements in the proposal are applied. Do you think that NCUA should allow comments on proposed guidance?
4. Should NCUA include a formal appeals process in the regulation if NCUA contexts a fixed asset investment when the CU has a FAM?
5. The proposal does not amend NCUA’s full occupancy requirements of premises that were acquired for future expansion. Should NCUA modify this rule?
6. Are there any other areas of the fixed assets rule that you would like to see updated?