Comment from State Employees' Credit Union

Summary: State Employees' Credit Union (SECU) supports the NCUA's action to clarify preemption authority regarding non-interest charges and fees but urges the Board to extend these protections to federally-insured, state-chartered credit unions (FISCUs). They argue that FISCUs face the same safety-and-soundness risks as federal credit unions regarding the Illinois Interchange Fee Prohibition Act (IFPA) and that failing to do so creates unfair competitive disparities.