We are most pleased to see that much needed regulatory relief appears to be moving forward in the legislative process.  Congressmen Hensarling and Moore have done an excellent job crafting a bill to provide important relief to the various stake-holders, and we appreciate their immense efforts to make this happen.  Additionally, we appreciate the continued support of Committee leadership in recognizing the importance of this initiative. 

We are especially pleased with several components of this bill intended to provide specific relief to community banks.  While there are certainly additional areas of regulatory burden falling disparately upon community banks we feel should be addressed, we strongly feel that it would be imprudent to push for amendments to this carefully crafted bill, as such action may jeopardize the ultimate chance of passage.

It has come to our attention that the credit union industry does not share this strategy, and are lobbying fervently for the inclusion of some very unpalatable provisions contained in “CURIA” (H.R. 2317).  We wish to go on record – again – as strongly and inalterably opposing any additional commercial lending powers for non-taxed financial institutions.  Additionally, we have substantial concerns regarding the lowering of capital standards for this industry – especially as they push for more risky lending authority.  Finally, we firmly believe that a financial institution should have the right to select a charter that best meets the needs of their various stakeholders.  We find the recent behavior of NCUA regarding the conversions of two Texas credit unions to mutual thrifts wholly unacceptable, as well as arbitrary and capricious. 

Additionally, it is important to point out that the provisions in CURIA are primarily powers issues rather than regulatory burden relief.  We strongly oppose CURIA, and feel that granting additional powers to a direct competitor who pays no taxes and operates in a much different regulatory environment is ill-advised and inappropriate.  We find the attempts to add additional powers to a regulatory burden relief initiative especially unsettling, and hope that Congress will allow this bill to move through the process without the baggage of highly controversial amendments.

Thank you for your consideration of our position on this important issue, and please let us know if we can provide any additional information.

Sincerely,

Christopher L. Williston, CAE                          Stephen Y. Scurlock

President and CEO                                           Executive Vice President