Texas Credit Union League Comment Call Training

Texas Credit Union LeagueComment Call Training Compelling Comment Letters

Increased Focus: Regulatory Advocacy NCUA TCUD Federal Reserve CFPB 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.

Worried about new regulatory burdens? Take action!

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 offerings You 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: Cost Time Staff expertise/training Some burdens aren’t always easily defined Member service/confidence Ability to assist in time of need One size does not fit all situations

Your Check list Reviewed Rule Your Credit Union • 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?

Are you prevented from helping your members? Tell THEIR story!

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 vital ex. Member relies on a twice monthly payments to control their costs

Step two: Illustrate with members’ stories Type of impact Member story • Fraud • Member A’s son uses debit card, running up $5k in bills

Step two: Illustrate with members’ stories Type of impact Member story • Staff time/costs • Member A relies on counseling, however we will have to redirect staff resources and limit this program

Step two: Illustrate with members’ stories Type of impact Member story • Decline in service delivery • Member A lives in remote area, served by branch • Member B relies on call center on weekends

Step two: Illustrate with members’ stories Type of impact Member story • Removing or hampering products that help members • Member A was saved from bankruptcy because of credit insurance

Step two: Illustrate with members’ stories Type of impact Member story • Bottom line costs passed onto members • Estimate cost to members

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.

Ready to write Construct your letter!

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

Send it! Now what? Texas two step!

Step four: Texas two step Copy the League Encourage others • 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)

Common Concerns • Retaliation at the regulator • Time it takes • Is there an impact?

Questions?

Texas Credit Union League Comment Call Training