Comment from The Endangered Small Credit Union Defense
The Endangered Small Credit Union DefenseSupportAdvocacy
Summary: The Endangered Small Credit Union Defense (ESCUD), an advocacy organization representing small credit unions, supports the NCUA's interim final rule clarifying federal authority to assess non-interest charges and fees. They argue that this rule provides essential regulatory certainty for small institutions, helps offset the costs of card programs, and prevents a patchwork of conflicting state laws from harming community-focused credit unions.
See attached file(s)