How to Write a Comment Letter

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The Process

When a regulator issues a proposal, there is a period of time set aside (usually 30-90 days) when the regulator encourages credit unions to offer comment. When the comment period ends, the regulator reviews submitted letters and determines if any changes should be made before issuing a final rule.

On behalf of our tri-state credit unions, the LSCU sends dozens of comment letters every year to regulatory agencies regarding the unnecessary hardships proposed rules pose, as well as unintended consequences. Comments from the LSCU are often incorporated into the final versions of proposed rules, thereby helping to lessen compliance burdens for credit unions.

How to Write a Comment Letter

When preparing a formal comment letter for submission to a regulatory agency, consider the following:

There should be an explicit, precise statement of the credit union's position. Use either a general statement at the beginning of the letter or individual statements for each specific provision.
Complaints should be kept to a minimum. They are ineffective and distract from a logical, well-supported argument.
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.
Positive recommendations to resolve potential problems are very useful.
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.
The letter should be signed by a member of senior management.
A copy of the final comment letter should also be sent to the LSCU’s Advocacy Department, so the credit union's comments can be incorporated into the LSCU’s comment letter.
Comment Letter Archives
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