Comment from ORNL Federal Credit Union

Summary: ORNL Federal Credit Union expresses that while it opposes the concept of credit unions merging into banks due to the loss of the cooperative model, it supports the NCUA's proposed modernization of communication requirements and the separation of binding rules from nonbinding guidance. The credit union requests that the final rule maintain strong protections for member notice, clear disclosures regarding the loss of ownership rights, and clear supervisory expectations for the voting process.