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SW&M Comments on NCUA's Notice of Proposed Rulemaking Regarding the Incentive-Based Compensation Arrangements

On July 21, 2016, our office responded to the NCUA’s Notice of Proposed Rulemaking Regarding the Incentive-Based Compensation Arrangements (the "Proposed Rule"). 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. With respect to the Proposed Rule, we believe that certain changes or clarifications could be made to assist credit unions in complying with its provisions and to ensure that the Proposed Rule fairly effectuates Congress's intent.