Comment from Self-Help Credit Union/Self-Help Federal Credit Union

Summary: Self-Help Credit Union and Self-Help Federal Credit Union oppose the proposed amendments to Subpart C of 12 CFR Part 708a, arguing that they lessen protections for credit union member-owners and decrease clarity regarding mergers with banks. They specifically express concern that removing "clear and conspicuous" definitions and certain disclosure requirements creates uncertainty and risks favoring for-profit banks over non-profit credit unions.