Credit Union National Association
District of Columbia
In the Matter of Holder Rule Review, FTC File No.P164800; Docket No. HHS--OPHS--2015--0008
The Credit Union National Association (CUNA) appreciates the opportunity to comment on the Federal Trade Commission's (FTC) systematic review of the efficiency, costs, benefits, and impact of the Trade Regulation Rule Concerning Preservation of Consumers' Claims and Defenses (Holder Rule). CUNA represents America's credit unions and their more than 100 million members.