March 23, 2007
Thank you for the opportunity to comment on your proposal which would exempt banks and thrifts from certain broker-dealer requirements. I am responding on behalf of a state-chartered credit union located in Virginia, with $1.4 billion in assets and over 170,000 members.
In the proposal, banks and thrifts would not be required to register as a broker-dealer if they engage in certain activities, such as third party brokerage networking arrangements. The proposal does not specifically exempt credit unions from registering as a broker-dealer for these same activities; therefore, we are requesting credit unions be covered under these same exceptions. We realize that all credit unions may not engage in some of these activities currently; however, we believe the same exceptions in the proposal for banks and thrifts should apply to credit unions should the opportunity to pursue these activities arise in the future, based on member demand and need.
Please feel free to contact me should you have any questions about our comments.