TEXAS CREDIT UNION LEAGUECOMMENT CALL TRAINING

Compelling Comment Letters

Increased Focus: Regulatory Advocacy

NCUATCUDFederal ReserveCFPB

Dodd-Frank repeal is unlikely. This means many changes and new regs.

Deadlines for implementation are quick.

Multiple (and new) regulators means less institutional understanding of credit union difference.

Regs need to hear from YOU in a compelling way.

Take action!Worried about new regulatory burdens?

Step one: Understanding the impact

Is my credit union directly impacted?

Review list of concerns highlighted by CUNA and TCUL

Remember:Impact doesn’t have to be limited to current product offeringsYou can also comment on impact on issues that affect the movement overall

Step one: Understanding the impact

Areas of impact for my credit union

Some straight forward burdens:CostTimeStaff expertise/training

Some burdens aren’t always easily definedMember service/confidenceAbility to assist in time of need

One size does not fit all situations

Your Check list

Review rule Review

CUNA/TCUL concerns

Product/service match?

Is there industry impact you want to weigh in on?

What is the burden in money, time, staff?

What will it do to your ability to serve your members?

How will it impact your future?

Reviewed Rule Your Credit Union

Tell THEIR story!

Are you prevented from helping your members?

Step two: Tell a story

Member stories are the most compelling

Do you have a member story that will illustrate the burden?ex. Member can’t access funds from overseas.ex. Member does not have life insurance; credit insurance is vitalex. Member relies on a twice monthly payments to control their costs

Step two: Illustrate with members’ stories

Fraud Member A’s son uses debit card, running up $5k in bills

Type of impact Member story

Step two: Illustrate with members’ stories

Staff time/costs Member A relies on counseling, however we will have to redirect staff resources and limit this program

Type of impact Member story

Step two: Illustrate with members’ stories

Decline in service delivery

Member A lives in remote area, served by branch

Member B relies on call center on weekends

Type of impact Member story

Step two: Illustrate with members’ stories

Removing or hampering products that help members

Member A was saved from bankruptcy because of credit insurance

Type of impact Member story

Step two: Illustrate with members’ stories

Bottom line costs passed onto members

Estimate cost to members

Type of impact Member story

Step two: Strike the right tone

Despite the temptation to be brutally direct, keep your tone professional

Avoid phrases that infer a lack of research on the part of the regulator

Think of this as providing a window to your credit union

Urge reconsideration, don’t demand it.

Positive works too – are there elements you feel are well constructed? Let them know.

Construct your letter!Ready to write

Step three: Crafting your letter Note the deadline

– the CUNA/TCUL deadline is typically earlier

Proper address and salutation

Subject line should include the reg #

Intro paragraph: Your CU Your FOM or

community The proposed reg

you are responding to

Use your own words Do not “cut and

paste” Include your

members

Texas two step!Send it! Now what?

Step four: Texas two step

Send a copy of your letter to syashewski@tcul.coop

Contact one peer and encourage them to respond

Include a copy of yours (if you are willing)

Copy the League Encourage others

Common Concerns Retaliation at

the regulator Time it takes Is there an

impact?

QUESTIONS?