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 League's Advocacy Department, so the credit union's comments can be incorporated into the League's comment letter.