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SW&M Comments on Emergency Mergers - Chartering and Field of Membership

On September 28, 2017, our office responded to the NCUA's Notice of Proposed Rulemaking Regarding Emergency Mergers. Our comments can be found here. Our comments are provided from the perspective of attorneys representing hundreds of credit unions, both state and federal, nationwide. We are involved in a large proportion of the mergers between credit unions, and the lawyers at our firm have worked on hundreds of mergers involving credit union clients.