Write Comment Letters That Work

Four tips for writing an effective comment letter.

April 28, 2011
KEYWORDS comment , ncua , proposed , rule
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With all of the recent regulatory changes, you may have felt your voice hasn’t been heard, especially considering the speed that regulations are changing and the fact that very little seems to change from the proposed rule to the final rule.

Well, you might be surprised that comment letters actually do work—maybe not always, but they certainly can help.

NCUA Board Chairman Debbie Matz recently posted a video on NCUA’s website to provide tips for writing effective comment letters. She points out that the NCUA Board recently made significant changes to its final rule on corporate credit unions based on 227 comment letters.

Here are Matz’s tips for writing effective comment letters:

1. Read proposed rules and other comments Visit the agency’s website for information about each NCUA proposed rule and the deadline for comments.

Prospective commenters can also use the NCUA website to view previously submitted comment letters written by other stakeholders.

2. Decide whether you support or oppose. Commenters may support certain provisions and oppose others, or support or oppose the entire proposal.

3. Consider unintended consequences. Read the preamble of each proposed rule to understand NCUA’s intent. Think about changes that credit unions might have to implement in order to comply with the proposal.

Then, write to NCUA about any unintended consequences the rule might create.

4. Propose alternative solutions. Commenters who oppose a proposed rule, whether in whole or in part, are encouraged to propose reasonable alternatives.

“The federal rulemaking process is often about striking the fairest possible balance between the requirements of the law, our mission to protect safety and soundness, and our effort to minimize any adverse impact on credit unions,” Matz says.

Watch Matz's video here.

BRIAN JOHNSON is senior compliance officer for PolicyWorks LLC, Des Moines, Iowa. Contact him at 866-518-0209.

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