a)
There should be an explicit, precise statement of the
credit union's position. This should be done by using
either a general statement at the beginning of the letter
or individual statements for each specific provision.
b) Complaints should be kept to a minimum. They are ineffective
and distract from a logical, well-supported argument.
c) Difficult issues in the proposal should be described
in detail, using specific examples and data to demonstrate
the nature of the problem. Estimates of cost of implementation,
especially if balanced with probable benefits, are very
convincing.
d) Positive recommendations to resolve potential problems
are very useful.
e) The letter should mention favorable provisions. It
is important for the regulators to be able to weigh various
provisions according to how many credit unions are helped
or hurt.
f) The letter should be signed by a member of senior management.
g) A copy of the final comment letter should also be sent
to the League's Advocacy Department, so the
credit union's comments can be incorporated into the League's
comment letter.
